State v. Hoff, 2016 MT 244

Victim I.L., born 2002, alleged Hoff sexually assaulted her repeatedly from about age 9–11; report made in July 2013 when she was 11. Hoff was arrested and denied the conduct.
DPHHS records produced in camera included references to alleged prior sexual‑assault accusations I.L. made at age four against two other men.
Hoff sought a Mazurek hearing to admit those prior accusations to impeach I.L.’s veracity under the three‑part Mazurek test (accusation made, shown to be false, and more probative than prejudicial).
The district court conducted in camera review of DPHHS files, closed the Mazurek hearing to the public, reviewed evidence, and ruled the prior accusations were not shown to be “in fact false,” excluding them from trial.
Hoff objected to closure, exclusion of the prior accusations at trial, and to the court’s refusal to disclose certain sealed DPHHS file contents; a jury later convicted Hoff of sexual assault and sexual intercourse without consent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether closing the Mazurek hearing violated Hoff’s public‑trial right	State: protecting minor’s confidentiality and DPHHS statutory privacy justifies closure	Hoff: closure not justified; redaction or partial openness would protect privacy and preserve public trial right	Affirmed closure; Waller factors satisfied given victim age, nature of allegations, sensitive identifying material, and lack of reasonable alternatives
Whether court erred in barring cross‑examination about prior accusations	State: prior accusations not admissible because Hoff failed to prove they were “in fact false” under Mazurek	Hoff: prior accusations were false and relevant to impeach I.L.’s credibility; court applied too strict a standard	Affirmed exclusion; court considered Hoff’s evidence and did not abuse discretion in finding accusations not shown to be false
Whether sealing/redacting DPHHS records violated Hoff’s due‑process/Brady/Ritchie rights	State: in camera review supports redactions to protect identity; no material favorable information withheld	Hoff: sealed records may contain material favorable evidence and should be disclosed	Affirmed sealing; in camera review by court and this Court found no material undisclosed information that would likely change outcome

Waller v. Georgia, 467 U.S. 39 (four‑part test for closing proceedings to the public)
Press‑Enterprise Co. v. Superior Court, 464 U.S. 501 (public‑trial presumption and required findings for closure)
Globe Newspaper Co. v. Superior Court, 457 U.S. 596 (compelling interest in protecting minor victims but requires case‑by‑case analysis)
Bell v. Jarvis, 236 F.3d 149 (trial court discretion in closing decisions; factual familiarity relevant)
State ex rel. Mazurek v. Dist. Court, 277 Mont. 349 (Montana test for admitting prior false accusations in sex‑offense cases)
State v. Anderson, 211 Mont. 272 (prior false accusation impeachment principles)
Miller v. State, 779 P.2d 87 (requirements for admitting prior allegations as impeachment evidence)
Pa. v. Ritchie, 480 U.S. 39 (due‑process/Brady principles applied to confidential child‑protective files)