Michigan v. Lucas

500 U.S. 145, 111 S. Ct. 1743, 114 L. Ed. 2d 205, 1991 U.S. LEXIS 2778
Supreme Court of the United States·Decided May 20, 1991·No. 90-149·Published·Cited by 504 cases

Opinions

Justice O’Connor

delivered the opinion of the Court.

Because Nolan Lucas failed to give statutorily required notice of his intention to present evidence of an alleged rape victim’s past sexual conduct, a Michigan trial court refused to let him present the evidence at trial. The Michigan Court of Appeals reversed, adopting a per se rule that preclusion of evidence of a rape victim’s prior sexual relationship with a criminal defendant violates the Sixth Amendment. We consider the propriety of this per se rule.

I — I

Like most States, Michigan has a rape-shield statute designed to protect victims of rape from being exposed at trial to harassing or irrelevant questions concerning their past sexual behavior. See Mich. Comp. Laws §750.520j (1979). [147] This statute prohibits a criminal defendant from introducing at trial evidence of an alleged rape victim’s past sexual conduct, subject to two exceptions. One of the exceptions is relevant here. It permits a defendant to introduce evidence of his own past sexual conduct with the victim, provided that he follows certain procedures. Specifically, a defendant who plans to present such evidence must file a written motion and an offer of proof “within 10 days” after he is arraigned. The trial court may hold “an in camera hearing to determine whether the proposed evidence is admissible” — i. e., whether the evidence is material and not more prejudicial than probative.

Lucas was charged with two counts of criminal sexual conduct. The State maintained that Lucas had used a knife to force his ex-girlfriend into his apartment, where he beat her and forced her to engage in several nonconsensual sex acts. At no time did Lucas file a written motion and offer of proof, as required by the statute. At the start of trial, however, Lucas’ counsel asked the trial court to permit the defense to present evidence of a prior sexual relationship between the girlfriend and Lucas, “even though I know it goes against the Statute.” App. 4.

[148] The trial court reviewed the statute and then denied the, motion, stating that “[n]one' of the requirements set forth in [the statute] have been complied with.” Id., at 7-8. The court explained that Lucas' request was not made within the time required by Michigan law and that, as a result, no in camera hearing had been held to determine whether the past sexual conduct evidence was admissible. A bench trial then began, in which Lucas’ defense was consent. The trial court did not credit his testimony. The court found Lucas guilty on two counts of criminal sexual assault and sentenced him to a prison term of 44 to 180 months.

The Michigan Court of Appeals reversed. Relying on People v. Williams, 95 Mich. App. 1, 289 N. W. 2d 863 (1980), rev’d on other grounds, 416 Mich. 25, 330 N. W. 2d 823 (1982), the Court of Appeals held that the State’s notice- and-hearing requirement is unconstitutional in all cases where it is used to preclude evidence of past sexual conduct between a rape victim and a criminal defendant. 160 Mich. App. 692, 694-695, 408 N. W. 2d 431, 432 (1987). The court quoted language from Williams stating that the requirement “ ‘serve[s] no useful purpose’ ” in such cases and therefore is insufficient to justify interference with a criminal defendant’s Sixth Amendment rights. 160 Mich. App., at 695, 408 N. W. 2d, at 432, quoting Williams, supra, at 10, 289 N. W. 2d, at 867. Williams surmised that the purpose of the notice-and-hearing requirement is “ ‘to allow the prosecution to investigate the validity of a defendant’s claim so as to better prepare to combat it at trial.’” 160 Mich. App., at 694, 408 N. W. 2d, at 432, quoting Williams, supra, at 10, 289 N. W. 2d, at 866. It concluded, however, that this rationale “‘loses its logical underpinnings’” when applied to evidence of past sexual conduct between the victim and the defendant because “ ‘the very nature of the evidence ... is personal between the parties’ ” and therefore impossible to investigate. 160 Mich. App., at 694, 408 N. W. 2d, at 432, quoting Williams, supra, at 10, 289 N. W. 2d, at 866-867.

[149] The Court of Appeals, relying on Williams, thus adopted a per se rule that the Michigan rape-shield statute is unconstitutional in a broad class of cases. Under this rule, a trial court would be unable to preclude past sexual conduct evidence even where a defendant’s failure to comply with the notice-and-hearing requirement is a deliberate ploy to delay the trial, surprise the prosecution, or harass the victim. We granted certiorari, 498 U. S. 980 (1990), to determine whether the Michigan Court of Appeals’ per se rule is consistent with our Sixth Amendment jurisprudence.

I — I h-f

Michigan s rape-shield statute is silent as to the consequences of a defendant’s failure to comply with the notice- and-hearing requirement. The trial court assumed, without explanation, that preclusion of the evidence was an authorized remedy. Assuming, arguendo, that the trial court was correct, the statute unquestionably implicates the Sixth Amendment. To the extent that it operates to prevent a criminal defendant from presenting relevant evidence, the defendant’s ability to confront adverse witnesses and present a defense is diminished. This does not necessarily render the statute unconstitutional. “[T]he right to present relevant testimony is not without limitation. The right ‘may, in appropriate cases, bow to accommodate other legitimate interests in the criminal trial process.’” Rock v. Arkansas, 483 U. S. 44, 55 (1987), quoting Chambers v. Mississippi, 410 U. S. 284, 295 (1973). We have explained, for example, that “trial judges retain wide latitude” to limit reasonably a criminal defendant’s right to cross-examine a witness “based on concerns about, among other things, harassment, prejudice, confusion of the issues,, the witness’ safety, or interrogation that is repetitive or only marginally relevant.” Delaware v. Van Arsdall, 475 U. S. 673, 679 (1986).

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Michigan v. Lucas, 500 U.S. 145, 111 S. Ct. 1743, 114 L. Ed. 2d 205, 1991 U.S. LEXIS 2778 (1991).

500 U.S. 145 (Michigan v. Lucas) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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