Stephens v. Miller - 13 F.3d 998 (7th Cir. 1994)

Rule:

Restrictions imposed by rape shield statutes, especially as they relate to a criminal defendant's right to testify, may not, however, be arbitrary or disproportionate to the purposes they are designed to serve. Rather, the state is required to evaluate whether the interests served by the rule justify the limitation imposed on the criminal defendant's right to testify.

Facts:

Lonnie K. Stephens was convicted of attempted rape. During trial, the trial court excluded some of Stephens’ statements pursuant to the Indiana Rape Shield Statute. Ind. Code § 3574-4. Stephens filed a petition for a writ of habeas corpus, which the district court denied. On appeal, Stephens argued that the trial court unconstitutionally applied the Indiana Rape Shield Statute by denying him his constitutional right to testify in his own defense by preventing him from stating his version of the events.

Issue:

Did the trial court unconstitutionally apply the Indiana Rape Shield Statute, thereby warranting the grant of Stephens’ petition for a writ of habeas corpus?

Answer:

No.

Conclusion:

The Court rejected Stephens’ argument, holding that his right to testify was not unlimited. The Indiana Rape Shield Statute was enacted to prevent a generalized inquiry into the past sexual conduct of the victim in order to avoid embarrassing her. The Court averred that Stephens was allowed to give his entire version of the facts, except for the excluded evidence. Accordingly, the trial court properly balanced the state’s interests with Stephens’ right to testify when it excluded the testimony at issue. Moreover, the Court noted that federal habeas actions did not lie for mere errors of state. Accordingly, the Court affirmed the order of the district court.