Jackson v. State of Nevada

A trial court’s denial of relevant police witness testimony regarding an alleged victim’s past false accusations of rape violates a defendant’s constitutional right to present a defense and confront witnesses.

Calvin Jackson was convicted of sexual assault in Nevada state court. During the trial, the court precluded evidence by police witnesses that the alleged victim had previously made false accusations of rape. The trial court ruled this evidence was immaterial. After exhausting his habeas appeals in state court, Jackson filed a petition in district court, asserting that the trial court’s ruling denied him his constitutional right to present a defense and confront witnesses against him. The district court denied relief. Jackson appealed. The Ninth Circuit found that the state court decisions violated Jackson’s constitutional rights and excluded highly relevant evidence. The Court ruled that the trial court’s determination of irrelevance was error. Further, the Court found that it was error for the state courts to rule that Jackson’s counsel failed to give sufficient advance notice of bringing past accusations as required under state law. The defense counsel’s written notice was sufficient, and the total exclusion of the relevant police witness testimony was disproportionate to the notice function that the state evidentiary rule was intended to serve. REVERSED and REMANDED.