State v. Hauer, 279 P.3d 149

Hauer was charged in district court with multiple PFMA counts, unlawful restraint, assault with a weapon, aggravated assault, and witness tampering, consolidated from city cases.
January 13, 2009: Couture reported assault; misdemeanor PFMA charged in City Court and later moved to the district court.
May 28, 2009: Couture reported a second assault; second misdemeanor PFMA charge added.
July 9, 2009: Bar incident where Couture, with a knife, was threatened; charges included unlawful restraint, assault with a weapon, and PFMA.
July 27, 2009: Argumen t and choking incident resulting in aggravated assault; witness tampering charge stemmed from pressuring Couture to recant.
At trial, the court granted a motion in limine excluding evidence that Couture was a cutter; Hauer testified in self-defense.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the court err in prohibiting testimony about Couture cutting herself?	Hauer	State	No reversible error; right to present defense not violated
Was there ineffective assistance for agreeing not to introduce cutter evidence?	Hauer	State	No ineffectiveness; counsel's actions were reasonable under Strickland

Holmes v. South Carolina, 547 U.S. 319 (U.S. 2006) (right to present a complete defense; but not absolute)
State v. Schaff, 2011 MT 19 (Mont. 2011) (due process; evidentiary decisions reviewed de novo)
Taylor v. Illinois, 484 U.S. 400 (U.S. 1988) (limits on admissibility of evidence; meritless objections unavailable)
Ahto, 1998 MT 200 (Mont. 1998) (limits on admissibility of evidence; defense right to present)
Deschon v. State, 2008 MT 380 (Mont. 2008) (character evidence; essential elements of defense)