Nevada v. Jackson

PETITIONER: Nevada, et al.
RESPONDENT: Calvin O'Neil Jackson
LOCATION: Virginia Division of Child Support Enforcement

DOCKET NO.: 12-694
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 569 US (2013)
GRANTED: Jun 03, 2013
DECIDED: Jun 03, 2013

Facts of the case

On October 22, 1998, Calvin O'Neil Jackson was arrested outside of his girlfriend's apartment. His girlfriend, Annette Heathmon, told the police that Jackson forced his way into her apartment, assaulted her, threatened to kill her with a screwdriver, and raped her. At trial, Heathmon testified that Jackson had previously sexually and physically assaulted her but had never been convicted of a crime. The defense attempted to call police officers to testify that Jackson's girlfriend's previous accusations were unconvincing and unsubstantiated by the evidence. The court barred this testimony and also refused to allow the defense to cross-examine Heathmon regarding alleged prior acts of prostitution. The jury found Jackson guilty of burglary, battery with intent to commit a crime, first degree kidnapping with a deadly weapon, and two counts of sexual assault with a deadly weapon.

Jackson appealed his conviction to the Supreme Court of Nevada and argued that the trial court's decision to exclude the evidence of Heathmon's previous accusations violated his right to present a defense. That court affirmed his conviction and stated that the excluded evidence was neither relevant nor material to his defense. Jackson then filed a habeas corpus claim based on the same argument. The district court denied his claim, holding that the state court's exclusion of police testimony did not violate Jackson's constitutional right to present a complete defense. The U.S. Court of Appeals for the Ninth Circuit reversed the district court's decision.

Question

Did Nevada's state courts deny a defendant's constitutional right to present a defense when they prevented the defendant from entering evidence that a rape victim's previous sexual assault claims were unsubstantiated?