Jackson v. Norris
2011 U.S. App. LEXIS 17739
8th Cir.2011Background
- Jackson was convicted in 2006 of first-degree sexual abuse and second-degree sexual assault of his wife's minor granddaughter, J.W.
- Arkansas trial court excluded evidence of J.W.’s prior sexual conduct under Arkansas rape shield statute after an in camera hearing.
- The state supreme court affirmed the exclusion, finding the prior conduct irrelevant to Jackson’s guilt.
- Jackson filed a federal habeas petition arguing the exclusion violated his right to present a defense under the Sixth and Fourteenth Amendments.
- The district court granted relief; on appeal this court reversed and denied the habeas petition, holding no constitutional error in the exclusion.
- Key issue centers on whether motive-related evidence about J.W.’s credibility and the context of the accusal should have been admitted despite rape-shield rules.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Right to present a complete defense | Jackson argues exclusion of motive-related evidence violated his right to present a complete defense. | Norris contends rape shield evidence was irrelevant and properly excluded to protect victims. | Not violated; evidence was irrelevant, so exclusion did not impair defense. |
| Arresting question of federal review standard | District court’s ruling should be affirmed as a correct application of federal law protecting defense rights. | Arkansas Supreme Court’s decision should be upheld as reasonable under 28 U.S.C. § 2254(d). | Reversed de novo; district court’s grant of habeas petition affirmed. |
Key Cases Cited
- Chambers v. Mississippi, 410 U.S. 284 (U.S. Supreme Court, 1973) (requires fair opportunity to present defenses and cross-examine to test credibility)
- Holmes v. South Carolina, 547 U.S. 319 (U.S. Supreme Court, 2006) (limits on excluding probative evidence in balancing test)
- Davis v. Alaska, 415 U.S. 308 (U.S. Supreme Court, 1974) (cross-examination to reveal bias and motive of witness)
- Olden v. Kentucky, 488 U.S. 227 (U.S. Supreme Court, 1988) (cross-examination for witness credibility)
- United States v. Turning Bear, 357 F.3d 730 (8th Cir. 2004) (right to present evidence relevant to witness veracity in child-sex cases)
- Stephens v. Miller, 13 F.3d 998 (7th Cir. 1994) (balancing rape-victim protection against defendant’s defense)
- Woodall v. State, 2011 Ark. 22 (Ark. 2011) (rape-shield statute allows limited relevance balancing; discretion for trial court)