Wednesday, December 4, 2013

Stephens v. Miller case brief

Stephens v. Miller case brief summary
13 F.3d 998 (7th Cir.), cert. denied, 513 U.S. 808 (1994)


CASE SYNOPSIS
Appellant sought review of an order of the United States District Court for the Northern District of Indiana, Fort Wayne Division, that convicted him of attempted rape and denied his petition for writ of habeas corpus.

CASE FACTS
Appellant was convicted of attempted rape. He filed a petition for a writ of habeas corpus. The district court denied his petition. Appellant sought review and the court affirmed the order. Appellant argued that the court misapplied the Indiana Rape Shield Statute. The court disagreed, noting that federal habeas actions did not lie for mere errors of state. Appellant claimed that the state unconstitutionally applied its 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.

DISCUSSION

  • The court rejected his 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. 
  • Appellant 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 appellant's right to testify when it excluded the testimony at issue. 
  • The court rejected his res gestae argument, as the use of the term res gestae, for purposes of federal law, was essentially obsolete.

CONCLUSION
The court affirmed the order of the district court that convicted appellant of attempted rape where the district court was not concerned with whether the state misapplied its own rape shield statute, and appellant was not denied his constitutional right to testify in his own defense where the trial court properly balanced the state's interests with appellant's right to testify when it excluded the testimony at issue.

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