Nevada v. Jackson, 133 S. Ct. 1990

Jackson was convicted of rape and related crimes after Heathmon testified to his forced entry, threats with a screwdriver, and assault, with injuries observed by police.
Jackson discussed Heathmon’s allegations with police; he claimed any sex was consensual, and acknowledged some striking but denied pulling her outside by the neck and hair.
Before trial, Heathmon recanted in a letter but later recanted that letter, claiming coercion by associates; she testified after police custody as a material witness.
Defense sought to admit extrinsic evidence and police reports of Heathmon’s prior, uncorroborated accusations against Jackson; the trial court limited their use.
Nevada law generally bars extrinsic evidence of a witness’s prior conduct to attack credibility, under Nev. Rev. Stat. §50.085(3), with Miller v. State creating a narrow exception requiring notice and a hearing.
Nevada Supreme Court upheld exclusion under state law, and the federal habeas court reviewed under AEDPA deferential standards.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether AEDPA deference supports postconviction relief.	Jackson (Petitioner) argues Nevada ruling unreasonably applied federal law.	Nevada argues decision was reasonable under AEDPA.	Yes; the state court decision was reasonable.
Whether Nevada’s exclusion of extrinsic evidence violated the right to present a complete defense.	Jackson contends exclusion denied defense credibility and cross-examination.	Nevada argues legitimate state evidentiary rule and limited exception were constitutional.	No; rule preserved legitimate interest and not clearly unconstitutional.
Whether Miller v. State’s notice requirement and hearing for prior false accusations violates the Constitution.	Jackson asserts notice/hearing requirement impermissibly restricts defense.	Nevada maintains procedural safeguard is valid and not clearly unconstitutional.	No; not clearly unconstitutional under governing precedents.

Crane v. Kentucky, 476 U.S. 683 (1986) (meaningful opportunity to present a defense while allowing evidentiary limits)
Trombetta v. California, 467 U.S. 479 (1984) (due process limits on evidence exclusion)
Holmes v. South Carolina, 547 U.S. 319 (2006) (state rules excluding evidence with legitimate aims permitted)
Scheffer v. United States, 523 U.S. 303 (1998) (evidence rules may be broad yet compatible with rights)
Abbott v. State, 122 Nev. 715 (2006) ( Nevada rule limiting extrinsic evidence to impeach credibility)
Miller v. State, 105 Nev. 497 (1989) (pre-trial notice and hearing for false-claim evidence in sexual assault cases)
Michigan v. Lucas, 500 U.S. 145 (1991) (pretrial notice not per se unconstitutional)
Delaware v. Fensterer, 474 U.S. 15 (1985) (Confrontation Clause satisfied by cross-examination)
Jordan v. Warden, 675 F.3d 586 (2012) (Sixth Circuit on cross-examination versus extrinsic evidence)
Davis v. Alaska, 415 U.S. 308 (1974) ( Confrontation concerns and cross-examination flexibility)
Olden v. Kentucky, 488 U.S. 227 (1988) (per curiam on confrontation principles)
Rock v. Arkansas, 483 U.S. 44 (1987) (limits on credibility-impeachment evidence)
Washington v. Texas, 388 U.S. 14 (1967) (rules on exclusion of evidence)
Chambers v. Mississippi, 410 U.S. 284 (1973) (fundamental fairness in procedure and defense presentation)
Davis v. Alaska, 415 U.S. 308 (1974) (cross-examination rights limitations)
Harrington v. Richter, 562 U.S. _ (2011) (AEDPA deference standard)