Calvin Jackson v. Robert Legrand, 2012 U.S. App. LEXIS 16292

Jackson was charged with 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.
He was convicted; district court barred police-witness testimony and cross-examination about prior acts of prostitution to challenge the complainant’s credibility.
He argued on direct appeal that exclusion violated his right to present a defense and confront the witness under the Sixth and Fourteenth Amendments.
Nevada Supreme Court upheld the evidentiary rulings, citing Miller v. Nevada and state rules on extrinsic impeachment.
After exhausting state remedies, Jackson filed a federal habeas petition under AEDPA, which the district court denied; the court granted a certificate of appeal on defense-right issues.
The Ninth Circuit held the exclusion of the police-witness testimony violated due process and was not harmless under Brecht, reversing and remanding for conditional habeas relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Right to present a complete defense violated?	Jackson argues exclusion of officers’ testimony barred his defense.	Nevada court reasoned evidence was immaterial or inadmissible under Miller and state rules.	Yes; exclusion was unconstitutional under the due process right to present a complete defense.
Was the exclusion an unreasonable application of clearly established federal law under AEDPA?	State court failed to balance relevance against evidentiary rules.	State court correctly applied Miller and Nevada rules.	No; but court remanded because overall weighing showed unreasonableness under AEDPA standards.
Confrontation/ impeachment limits regarding prior prostitution evidence?	Cross-examining Heathmon about prior prostitution was necessary for credibility impeachment.	Court properly limited irrelevant or prejudicial lines of questioning.	The limitation did not amount to a constitutional violation; the confrontation right was not violated by this limit.

Washington v. Texas, 388 U.S. 14 (1967) (right to present a defense includes ability to call witnesses)
Crane v. Kentucky, 476 U.S. 683 (1986) (right to a meaningful opportunity to present a defense; limits apply)
Chambers v. Mississippi, 410 U.S. 284 (1973) (fundamental fairness requires admissibility of critical evidence; witnesses)
Davis v. Alaska, 415 U.S. 308 (1974) (impeachment by evidence of prior criminal convictions; relevance to credibility)
Lucas v. Michigan, 500 U.S. 145 (1991) (notice/hearing requirements may be constitutional if not arbitrary or disproportionate)