Law School Case Brief
Olden v. Kentucky - 488 U.S. 227, 109 S. Ct. 480 (1988)
A criminal defendant states a violation of the Confrontation Clause by showing that he was prohibited from engaging in otherwise appropriate cross-examination designed to show a prototypical form of bias on the part of the witness, and thereby to expose to the jury the facts from which jurors could appropriately draw inferences relating to the reliability of the witness.
Petitioner, James Olden, and his friend Charlie Ray Harris, who are both black, were charged with the kidnaping, rape, and forcible sodomy of Starla Matthews, a white woman. In his defense, petitioner asserted that he and Matthews had engaged in consensual sex, an account corroborated by several witnesses. Matthews' story was corroborated only by the testimony of one Russell. In order to show that Matthews had a motive to lie, petitioner wanted to introduce evidence that Matthews and Russell were living together at the time of the trial. However, the trial court granted the prosecutor's motion to keep such evidence from the jury and sustained the prosecutor's objection when the defense attempted to cross-examine Matthews about the matter after she had testified that she was living with her mother. The jury acquitted Harris of all charges and found petitioner guilty only of forcible sodomy. On appeal, petitioner claimed, inter alia, that the court's failure to allow him to impeach Matthews' testimony deprived him of his Sixth Amendment right to confront the witnesses against him. The Court of Appeals of Kentucky upheld the conviction. While acknowledging the relevance of the testimony, it found that the probative value of the evidence was outweighed by the possibility of prejudice against Matthews that might result from revealing her interracial relationship to the jury.
Did the state appellate court fail to accord proper weight to the petitioner’s Sixth Amendment right to confrontation?
The United States Supreme Court held that the state appellate court failed to accord proper weight to the prisoner's Sixth Amendment right to confrontation. According to the Court, the Sixth Amendment right to confrontation, incorporated in the Fourteenth Amendment and available in state proceedings, included the right to conduct reasonable cross-examination. In this case, the prisoner consistently asserted that he and the victim engaged in consensual sexual acts and that the victim, out of fear of jeopardizing her relationship with the codefendant, lied when she told the codefendant that she had been raped and had continued to lie since. The Court ruled that it was plain that a reasonable jury might have received a significantly different impression of the witness's credibility had defense counsel been permitted to pursue his proposed line of cross-examination.
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