Daniel Hanson v. David Beth, 738 F.3d 158

On June 29, 2006 Deputy Eric Klinkhammer stopped Daniel Hanson for speeding; an altercation ensued and Hanson drove away, later stopping at a red light and being arrested.
Hanson was charged under Wisconsin’s felony fleeing-and-eluding statute, Wis. Stat. § 346.04(3).
At trial Hanson claimed he fled in self-defense because he reasonably feared for his safety and sought to introduce testimony that Klinkhammer had a reputation for being “confrontational, aggressive and hot-tempered.”
Hanson did not claim prior knowledge of the officer’s reputation; he offered the evidence as propensity proof that the officer likely acted aggressively during the stop.
The trial court excluded the evidence under Wisconsin’s analogue to Fed. R. Evid. 404(a); the conviction was affirmed by the Wisconsin Court of Appeals and the Wisconsin Supreme Court.
Hanson filed a federal habeas petition arguing the evidentiary exclusion violated his constitutional right to present an effective defense; the Seventh Circuit affirmed denial of the writ.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether excluding third-party propensity evidence about the officer violated Hanson’s right to present a defense	Exclusion deprived Hanson of relevant evidence to corroborate his self-defense claim and was arbitrary/disproportionate under Holmes/Rock	Wisconsin’s rule (§ 904.04(1)(b)) properly limits propensity evidence; exclusion serves to avoid confusion and prejudice and did not bar Hanson from presenting his defense	Court held exclusion did not violate clearly established federal law; state court’s decision was not contrary to or an unreasonable application of Supreme Court precedent
Whether the Wisconsin Supreme Court’s reasoning (limited discussion) amounts to an unreasonable application of federal law under § 2254(d)	The state court failed to apply the Holmes/Rock balancing test and offered no connecting rationale	Even without explicit citations, the state court’s result and reasoning were consistent with Supreme Court limits on evidentiary rules; habeas review is deferential	Court held the state decision was within the range of reasonable applications of Supreme Court precedents and denied the habeas petition

Estelle v. McGuire, 502 U.S. 62 (state evidentiary rulings are not reviewable as state-law matters on federal habeas)
Chambers v. Mississippi, 410 U.S. 284 (right to present a defense; due process limits on evidence exclusion)
Holmes v. South Carolina, 547 U.S. 319 (evidence rules must yield where arbitrary or disproportionate to important defendant interests)
Rock v. Arkansas, 483 U.S. 44 (state rules may not be applied mechanistically to defeat the ends of justice)
Taylor v. Illinois, 484 U.S. 400 (limitations on right to present a defense where evidence is inadmissible under standard rules)
United States v. Scheffer, 523 U.S. 303 (rulemakers have broad latitude to exclude evidence)
Early v. Packer, 537 U.S. 3 (state court need not cite federal cases so long as result/reasoning do not contradict them)
Brown v. Payton, 544 U.S. 133 (definition of “contrary to” and “unreasonable application” under § 2254(d))
Harrington v. Richter, 562 U.S. 86 (deferential standard for unreasonable-application review)
Michelson v. United States, 335 U.S. 469 (rationale for excluding character evidence: prevent confusion and undue prejudice)
Montana v. Egelhoff, 518 U.S. 37 (many familiar evidentiary rules are constitutional exclusions of relevant evidence)