Nevada v. Jackson
569 U.S. 505
| SCOTUS | 2013Background
- Respondent was convicted of rape and related offenses after trial in which the defense sought to admit extrinsic evidence of the victim's prior reports of abuse, which the state court excluded.
- The Nevada Supreme Court upheld the exclusion, finding no constitutional error in applying Nev. Rev. Stat. § 50.085(3) and Miller v. State's notice/hearing requirement.
- Respondent challenged the ruling in federal habeas, arguing the exclusion violated his right to present a complete defense under the Constitution.
- The Ninth Circuit granted relief, holding the evidentiary ruling unconstitutional under AEDPA because the exclusion prejudiced respondent's defense and was an unreasonable application of Supreme Court precedents.
- The Supreme Court granted certiorari to resolve whether the Nevada rule and its application were consistent with the Constitution and AEDPA standards.
- The Court held that AEDPA deferential review was applied properly and that the Nevada Supreme Court reasonably applied controlling Supreme Court precedents.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether AEDPA review id applies deference to state court rulings on evidentiary claims | Jackson | Nevada | Reasonable application of federal law under AEDPA |
| Whether the exclusion of extrinsic evidence of prior false accusations violated the right to present a complete defense | Jackson | Nevada | Not violated; state rule valid and constitutional under current precedents |
| Whether Miller v. State or Nev. § 50.085(3) unconstitutionally precluded relevant impeachment evidence | Jackson | Nevada | Not unconstitutional; no case-by-case balancing required |
| Whether the Ninth Circuit erred by treating cross-examination rights as a right to extrinsic impeachment evidence | Jackson | Nevada | Ninth Circuit erred; Confrontation Clause does not guarantee extrinsic impeachment evidence |
Key Cases Cited
- Chambers v. Mississippi, 410 U.S. 284 (U.S. 1973) (right to present a meaningful defense; limits on evidence admissibility)
- California v. Trombetta, 467 U.S. 479 (U.S. 1984) (policies governing collection and admissibility of evidence)
- Crane v. Kentucky, 476 U.S. 683 (U.S. 1986) (meaningful opportunity to present a complete defense)
- Holmes v. South Carolina, 547 U.S. 319 (U.S. 2006) (limits on admissibility of evidence; balancing not automatic)
- United States v. Scheffer, 523 U.S. 303 (U.S. 1998) (limits on certain types of evidence; military and evidentiary rules)
- Rock v. Arkansas, 483 U.S. 44 (U.S. 1987) (regulation of admissible testimony; due process considerations)
- Washington v. Texas, 388 U.S. 14 (U.S. 1967) (confrontation and cross-examination rights)
- Davis v. Alaska, 415 U.S. 308 (U.S. 1974) (cross-examination and credibility of witnesses)
- Delaware v. Fensterer, 474 U.S. 15 (U.S. 1985) (cross-examination and confrontation concerns)
- Olden v. Kentucky, 488 U.S. 227 (U.S. 1988) (confrontation and evidence issues per curiam)
- Michigan v. Lucas, 500 U.S. 145 (U.S. 1991) (pretrial notice and admissibility of prior relationships evidence)