As a matter affecting credibility, a defendant has a right to inquire about any interest, bias, or motive to testify falsely on the part of a witness. ( People v. Baugh (1981), 96 Ill. App.3d 946.) Impeachment of a witness for the purpose of showing bias in testifying is an important function of the constitutionally protected right of cross-examination. People v. Betts (1983), 116 Ill. App.3d 551.
The key factor is not the existence of actual pressure, but the witness' state of mind. ( People v. Baugh (1981), 96 Ill. App.3d 946, 951, 422 N.E.2d 166.) Where the witness is in a position to contemplate the possibility of leniency or favor, the defendant should be allowed to question the witness concerning these matters.
The key factor is not the existence of actual pressure, but the witness's state of mind. People v. Baugh, 96 Ill.App.3d 946, 951, 52 Ill.Dec. 485, 422 N.E.2d 166 (1981). Where the witness is in a position to contemplate the possibility of leniency or favor, the defendant should be allowed to question the witness concerning these matters.
• 5 If the record reflects that the jury has been made aware of adequate areas of impeachment of the witness, the prohibition of further cross-examination does not result in error. ( People v. Lindgren (1982), 111 Ill. App.3d 112, 443 N.E.2d 1129; People v. Baugh (1981), 96 Ill. App.3d 946, 422 N.E.2d 166.) Additionally, there is no abuse of discretion in restricting cross-examination when, as here, the jury is informed that the witness has been charged with a crime and that there has been no promise of leniency in exchange for the witness' testimony.
We find the Lindgren holding controlling. • 3 As a further basis for our holding we note that the court in People v. Baugh (1981), 96 Ill. App.3d 946, 951, 422 N.E.2d 166, 171, stated: "The issue under the confrontation clause is whether the jury has been made aware of adequate factors to determine whether a witness is worthy of belief, not whether any particular limitation has been placed upon defendant's ability to cross-examine a witness or whether the jury has knowledge of any specific fact. [Citations.] Thus, if it appears from the entire record that the jury has been made aware of adequate factors concerning relevant areas of impeachment of a witness, no constitutional question arises merely because defendant has been prohibited, on cross-examination, from pursuing other areas of inquiry. [Citation.]"
• 3 Finally, in determining whether a defendant has been denied the right to confront witnesses against him, a court must look to what was allowed, not what was prohibited. ( People v. Baugh (1981), 96 Ill. App.3d 946, 422 N.E.2d 166.) If the jury is made fully aware of all the factors concerning the relevant areas of impeachment, there is no denial of the right to confront. The jury was told that Lewis had pleaded guilty to reduced charges and had been released on her own recognizance in exchange for her testimony.
( People v. Hines (1981), 94 Ill. App.3d 1041, 1048, 419 N.E.2d 420.) See also People v. Baugh (1981), 96 Ill. App.3d 946, 951, 422 N.E.2d 166. • 4 Although we find no constitutional violation, we do find that the trial court's limitation of defense counsel's cross-examination of Grover Evans was improper under the law of evidence.