Commonwealth v. Stockhammer case brief
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409 Mass. 867, 570 N.E.2d 992, 1991
Mass.
CASE SYNOPSIS: Defendant sought review
of his conviction after a jury-waived trial in the Superior Court
Department (Massachusetts) on charges of rape and assault with intent
to commit rape.
FACTS: Defendant and complainant were college freshman. After a sexual incident, complainant confidentially told friends that she was raped by defendant. Defendant was later invited to visit complainant's home, and complainant broke up with her regular boyfriend. Months after the sexual incident, complainant, at the prompting of her father who learned of the incident through an anonymous call, reported to police that defendant raped her. Complainant received psychiatric treatment by psychiatrists and counselors. After an in camera inspection of the complainant's psychiatric records, the trial court refused to disclose them to defendant. The trial judge also ruled that defendant could not question complainant about her sexual activity to establish her consent, bias, and motive to falsify testimony. Defendant was convicted.
HOLDING:
On appeal, the court held that the evidence was sufficient to support the conviction.
ANALYSIS:
However, the court reversed the conviction because the trial court erred in precluding relevant cross-examination of complainant and because privileges prohibiting disclosure of psychiatric records yielded to defendant's state constitutional right to confront his accuser.
CONCLUSION: The court reversed defendant's conviction on charges of rape and assault with intent to commit rape because the trial court erred in precluding relevant cross-examination concerning complainant's sexual activity to establish her consent, bias, and motive to falsify testimony, and because privileges prohibiting disclosure of psychiatric records yielded to defendant's state constitutional right to confront his accuser.
FACTS: Defendant and complainant were college freshman. After a sexual incident, complainant confidentially told friends that she was raped by defendant. Defendant was later invited to visit complainant's home, and complainant broke up with her regular boyfriend. Months after the sexual incident, complainant, at the prompting of her father who learned of the incident through an anonymous call, reported to police that defendant raped her. Complainant received psychiatric treatment by psychiatrists and counselors. After an in camera inspection of the complainant's psychiatric records, the trial court refused to disclose them to defendant. The trial judge also ruled that defendant could not question complainant about her sexual activity to establish her consent, bias, and motive to falsify testimony. Defendant was convicted.
HOLDING:
On appeal, the court held that the evidence was sufficient to support the conviction.
ANALYSIS:
However, the court reversed the conviction because the trial court erred in precluding relevant cross-examination of complainant and because privileges prohibiting disclosure of psychiatric records yielded to defendant's state constitutional right to confront his accuser.
CONCLUSION: The court reversed defendant's conviction on charges of rape and assault with intent to commit rape because the trial court erred in precluding relevant cross-examination concerning complainant's sexual activity to establish her consent, bias, and motive to falsify testimony, and because privileges prohibiting disclosure of psychiatric records yielded to defendant's state constitutional right to confront his accuser.
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Interested in learning how to get the top grades in your law school classes? Want to learn how to study smarter than your competition? Interested in transferring to a high ranked school?
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