State v. Goins, 244 N.C. App. 499 (Dec. 15, 2015)

In this sexual assault case involving allegations that the defendant, a high school wrestling coach, sexually assaulted wrestlers, the trial court abused its discretion by excluding, under Rule 403, evidence that one of the victims was biased. The evidence in question had a direct relationship to the incident at issue. Here, the defendant did not seek to introduce evidence of completely unrelated sexual conduct at trial. Instead, the defendant sought to introduce evidence that the victim told “police and his wife that he was addicted to porn . . . [and had] an extramarital affair[,] . . . [in part] because of what [Defendant] did to him.” The defendant sought to use this evidence to show that the victim “had a reason to fabricate his allegations against Defendant – to mitigate things with his wife and protect his military career.” Thus, there was a direct link between the proffered evidence and the incident in question. The court went on to hold, however, that because of the strong evidence of guilt, no prejudice resulted from the trial court’s error.