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Clause “protects a defendant’s ability to prove a witness’s motive or bias,” it does not deprive trial courts of their “wide 11 STATE v. ORDWAY Decision of the Court latitude to impose reasonable limits on cross-examination” to avoid, “among other things, confusion of the issues.” -98, ¶ 22 (App. 2013) (citing Delaware v. Van Arsdall, 475 U.S. 673, 679 (1986)).

See Davis v. Alaska, 415 U.S. 308, 316-17 (1974) (“[E]xposure of a witness’ motivation in testifying is a proper and important function of the constitutionally protected right of cross-examination.”); ¶ 22 (App. 2013) (“The Sixth Amendment [to the U.S. Constitution] protects a defendant’s ability to prove a witness’s motive or bias.”).

( ¶ 5 (App. 2013)), and the failure to do so constitutes fundamental error,” id.

This guarantee includes the opportunity “to prove a witness’s motive or bias.” see also Davis v. Alaska, 415 U.S. 308, 316-17 (1974) (“[E]xposure of a witness’ motivation in testifying is a proper and important function of the constitutionally protected right of cross-examination.”).

(stating that the brevity of inadmissible testimony was relevant to upholding denial of mistrial); ¶ 29 (App. 2013) (finding no reasonable probability that the jury was influenced by isolated testimony that was not mentioned again).

But “the court has an independent duty to instruct on the law when the matter is vital to a proper consideration of the evidence, even if the particular instruction is not requested,” ¶ 5 (App. 2013), and the failure to do so constitutes fundamental error, ¶ 11 (App. 2009) (“With regard to jury instructions, fundamental error occurs when the trial judge fails to instruct upon matters vital to a proper consideration of the evidence.”) (internal quotation

¶ 6 (App. 2013) (noting a “defendant is entitled to a jury instruction on justification when he presents the ‘slightest evidence’ tending to prove a ‘hostile demonstration’”) (citation omitted).

¶ 5 (App. 2013) 4 STATE v. GERI Decision of the Court (citation omitted).

¶ 29 (App. 3 STATE v. TUCKER Decision of the Court 2013) (“[J]urors are presumed to follow the trial court’s instructions, including curative ones.”); (con

a proximate-cause instruction [need not] be given whenever a causation issue is raised.” n.6, ¶ 17 (App. 2013); see also Mott, 187 Ariz. at 546 (proximate cause 6 STATE v. SOMMERFIELD Decision of the Court instruction not required when the instructions given “instruct the jury on the elements of the crime

:ama 4 Moreover, any possible error was, on this record, harmless “because it did not contribute to or affect the verdict.” ¶ 25, (citing Gertz, 186 Ariz. at 42, 918 P.2d at 1060; Van Arsdall, 475 U.S. at 682).

In re Harber’s Estate, ¶ 19 (App. 2013).

Cf. In re Harber’s Estate

404(b) (allowing admission of other act evidence to prove motive, even when same evidence inadmissible to prove action in conformity therewith); ¶ 22, (Confrontation Clause “protects a defendant’s ability to prove a witness’s motive or bias”).