Idaho Supreme Court Announces False Rape Allegations May Be Admitted Regardless of When Made
Steven Michael Chambers was charged with raping N.S. in June 2016. N.S. claimed she met Chambers at his house, that he punched her in the abdomen, and then forced himself on top of her while raping her.
During preliminary hearings, Chambers sought to admit evidence per I.R.E. 412 that, six months after N.S. alleged he raped her, N.S. filed an identical claim against another man, and the detective in that case declined to arrest or charge the suspect. Indeed, the suspect claimed N.S. had visited him and had consensual sex, and the suspect was cooperative to the point of passing a polygraph test. Further, evidence showed N.S. had deleted all text messages, including sexting and provocative photos, from her phone after contacting 911 in both cases.
The trial court interpreted the language of I.R.E. 412 as not permitting the evidence because the other allegation occurred after N.S. accused Chambers and was therefore not “made at an earlier time.” The court also determined the evidence would result in a “confusion of the issues,” a “mini-trial within the case,” and “unfair prejudice.”
Chambers entered a conditional Alford plea and was sentenced to a 10-year unified sentence with two years fixed, which was suspended in favor of three years of supervised probation. Chambers then timely appealed.
The Idaho Supreme Court analyzed the text of Rule 412. Since it is a judicial rule and not a statute, its analysis merely begins with the rule’s wording but also “may be tempered by the rule’s purpose.” State v. Montgomery, 408 P.3d 38 (Id. 2017).
Rule 412 is part of a jurisprudence known as “rape shield laws.” It prevents defendants from admitting evidence of a victim’s prior sexual behavior to prevent “potential embarrassment and sexual stereotyping.” See Fed. R. Evid. 412’s note on its 1994 amendment. However, because a history of false rape allegations can, and should, affect a victim’s credibility, I.R.E. 412 allows for the admission of “false allegations of sex crimes made at an earlier time.”
While the district court rejected the admissibility of the evidence of N.S.’s other rape allegation because it occurred after her claim against Chambers, the Idaho Supreme Court found no such temporal requirement. Referring to the model rules the judicial committee likely used to draft the rule in 1987, the note to the model rule states, “[i]t matters not that the sexual behavior took place after the alleged offense but before trial rather than before the alleged offense.”
The Idaho Supreme Court also decided that the district court applied a conflicting test under Rule 403, instead of the proper test under Rule 412, because the test for the latter only mentions “unfair prejudice,” not “confusion of the issues” or “misleading the jury” as the former does.
The Court announced a three-part test for courts going forward to determine whether evidence of a purported false allegation is admissible as follows: (1) the district court must determine, by a preponderance of the evidence, whether “the allegations of the purported victim are false,” (2) whether the evidence is relevant to the current offense and (3) whether “the probative value of such evidence outweighs the danger of unfair prejudice.”
Related legal case
State v. Chambers
|Cite||465 P.3d 1076 (Ida. 2020)|
|Level||Court of Appeals|