State v. Patterson
291 P.3d 556
Mont.2012Background
- Patterson was charged in Montana with multiple counts of sexual offenses against five victims, including two 11-year-olds, with events in Miles City, Montana.
- DNA testing of a stain on the victim A.K.'s shirt did not match Patterson, leading to a pretrial rape shield motion to exclude such DNA testimony.
- The District Court granted the rape shield motion and allowed only limited DNA testimony relating to non-matching results and non-Patterson DNA.
- At trial, the State proceeded on Counts I, II, III, IV, V, with Count V later dismissed for insufficiency of evidence; Patterson was convicted on Counts I, III, and IV, and acquitted on Count II.
- Patterson was sentenced to concurrent long prison terms on Counts I, III, and IV, with the events surrounding the offenses occurring at his home in Miles City.
- On appeal, Patterson challenged the rape shield ruling and the venue ruling for Counts I and IV.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Rape shield application and fair trial | Patterson contends the shield violated fair trial rights by excluding the DNA evidence. | Patterson argues exception for origin of semen/disease should admit relevant evidence. | No reversible error; statute properly applied. |
| Venue proof for Counts I and IV | State failed to prove venue in Custer County for Counts I and IV. | Venue established by witnesses' testimony placing offenses at Patterson's home in Miles City. | Venue properly proven; no error in denying dismissal. |
Key Cases Cited
- State v. Bauer, 308 Mont. 99, 39 P.3d 689 (Mont. 2002) (rape shield DNA ruling; timing of evidence)
- State v. Johnson, 288 Mont. 513, 958 P.2d 1182 (Mont. 1998) (rape shield and limiting intrusion into trial)
- State v. Van Pelt, 247 Mont. 99, 805 P.2d 549 (Mont. 1991) (curtailment of rape shield to protect trial integrity)
- State ex rel. Mazurek v. Dist. Court, 277 Mont. 349, 922 P.2d 474 (Mont. 1996) (limited admissibility of victim's sexual history)
- State v. Galpin, 2003 MT 324, 318 Mont. 318, 80 P.3d 1207 (Mont. 2003) (venue proof and circumstantial evidence standards)
- State v. Diesen, 2000 MT 1, 297 Mont. 459, 992 P.2d 1287 (Mont. 2000) (venue is jurisdictional fact; de novo review)
- State v. Howell, 254 Mont. 438, 839 P.2d 87 (Mont. 1992) (rape shield discretion and victim privacy)
- Chambers v. Mississippi, 410 U.S. 284 (U.S. 1973) (due process; exclusion of other-perpetrator evidence)