The question is whether evidence that Pyle made a threatening call to Franco after the criminal offense was relevant to show that Pyle was motivated to exaggerate the amount of the losses he sustained as the result of the theft. We conclude that such evidence, offered for that purpose, would have been relevant to show bias. Therefore, Franco was entitled, as a matter of Due Process, to explore Pyle’s potential bias, as evidenced by Pyle having made a threatening call to Franco after the criminal incident. By precluding that inquiry, the Superior Court erred. We conclude, nonetheless, that although the trial court erred, the error was harmless. “Violations of the minimal due process right to confrontation ar , 1102-03 (3d Cir.1990); State v. McGill, 213 Ariz. 147, 140 P.3d 930 (2006) (<HOLDING>); United States v. Rondeau, 430 F.3d 44, 47
holding that the confrontation clause applies only to trials and not to sentencing hearings holding that the confrontation clause does not apply to the sentencing hearing holding that confrontation clause protections do not extend to sentencing hearings holding the confrontation clause applies only to testimonial statements holding that the confrontation clause applies only to testimonial hearsay