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State v. Chambers

Court of Appeals of Idaho

April 29, 2019

STATE OF IDAHO, Plaintiff-Respondent,
v.
STEVEN MICHAEL CHAMBERS, Defendant-Appellant.

          Appeal from the District Court of the First Judicial District, State of Idaho, Kootenai County. Hon. Scott Wayman, District Judge.

         Judgment of conviction for battery with intent to commit a serious felony, affirmed.

          Eric D. Fredericksen, State Appellate Public Defender; Lara E. Anderson, Deputy Appellate Public Defender, Boise, for appellant. Lara E. Anderson argued.

          Hon. Lawrence G. Wasden, Attorney General; Mark W. Olson, Deputy Attorney General, Boise, for respondent. Mark W. Olson argued.

          LORELLO, JUDGE

         Steven Michael Chambers appeals from his judgment of conviction for battery with intent to commit a serious felony. Chambers argues that the district court erred by excluding evidence under I.R.E. 412. For the reasons set forth below, we affirm.

         I. FACTUAL AND PROCEDURAL BACKGROUND

         The State charged Chambers with rape after the victim reported to police that Chambers had forcible sexual intercourse with her. Chambers filed a motion pursuant to I.R.E. 412, requesting permission to introduce evidence that the victim made a "false allegation of rape" against a different individual approximately six months after the alleged rape by Chambers. The State objected to the admission of such evidence. The district court held that the evidence was inadmissible under I.R.E. 412 and under I.R.E. 403. Chambers subsequently entered an Alford[1]plea to an amended charge of battery with the intent to commit a serious felony, reserving his right to appeal the district court's ruling on his I.R.E. 412 motion. Chambers appeals.

         II. STANDARD OF REVIEW

         The interpretation of a court rule is subject to de novo review. See State v. Montgomery, 163 Idaho 40, 42-43, 408 P.3d 38, 40-41 (2017). A trial court's determination that evidence is relevant is also reviewed de novo, but a trial court's determination under I.R.E. 403 is reviewed for an abuse of discretion. State v. Kopsa, 126 Idaho 512, 520-521, 887 P.2d 57, 65-66 (Ct. App. 1994). When a trial court's discretionary decision is reviewed on appeal, the appellate court conducts a multi-tiered inquiry to determine whether the lower court: (1) correctly perceived the issue as one of discretion; (2) acted within the boundaries of such discretion; (3) acted consistently with any legal standards applicable to the specific choices before it; and (4) reached its decision by an exercise of reason. State v. Herrera, 164 Idaho 261, 270, 429 P.3d 149, 158 (2018).

         III. ANALYSIS

         Chambers contends the district court abused its discretion by "misapplying [I.R.E.] 412, and the Idaho Rules of Evidence as a whole, to the proffered false rape allegation evidence" when it concluded that I.R.E. 412 required the false allegation to precede the act underlying the offense charged in this case.[2] Chambers also contends that the district court abused its discretion in excluding the evidence under I.R.E. 403 and in "failing to consider the effect the exclusion of the evidence would have" on his constitutional right to present a defense. The State responds that the district court correctly interpreted I.R.E. 412's temporal requirement and that, even if the district court's interpretation of I.R.E. 412 was incorrect, the proffered evidence was properly excluded under I.R.E. 403. The State also contends that Chambers' constitutional claim is not preserved. We hold that although the district court erred in its interpretation of I.R.E. 412, it did not err in excluding the evidence Chambers sought to admit pursuant to that rule.

         A. Admissibility Under Idaho Rule of Evidence 412

         Interpretation of a court rule must begin with the plain, ordinary meaning of the language used in the rule. However, interpretation of the rule's language may be tempered by the purpose of the rule. Montgomery, 163 Idaho at 44, 408 P.3d at 42. This Court will not interpret a rule in a way that would produce an absurd result. Id. Instead, the Idaho Rules of Evidence are to be construed in a manner consistent with administering every proceeding fairly, eliminating unjustifiable expense and delay, promoting the development of evidence law, ascertaining the truth, and securing a just determination. I.R.E. 102; see Montgomery, 163 Idaho at 44, 408 P.3d at 42.

         Idaho Rule of Evidence 412 governs the admissibility of evidence related to the "past sexual behavior" of a victim in cases where the defendant is charged with a sex crime. The 2017 version of I.R.E. 412 controls the issue in this case.[3] The relevant part of the rule at the time provided that (notwithstanding any other provision of law) in a criminal case in which a person is accused of a sex crime, evidence of a victim's past sexual behavior, other than reputation or opinion evidence, is not admissible. I.R.E. 412(b). The rationale underlying the prohibition on such evidence has been explained as protecting rape victims against unwarranted invasions of privacy and harassment regarding their sexual conduct. State v. Ozuna, 155 Idaho 697, 702, 316 P.3d 109, 114 (Ct. App. 2013); see Michigan v. Lucas, 500 U.S. 145, 149-50 (1991); Delaware v. VanArsdall, 475 U.S. 673, 679 (1986). The rule, however, provided four exceptions to this general limitation. I.R.E. 412(b)(2). These exceptions included:

(A) past sexual behavior with persons other than the accused, offered by the accused upon the issue of whether the accused was or was not, with respect to the alleged victim, the source of semen or injury; or
(B) past sexual behavior with the accused and is offered by the accused upon the issue of whether the alleged victim consented to the sexual behavior with respect to which the sex crime is alleged; or
(C) false allegations of sex crimes made at an earlier time[4]; or
(D) sexual behavior with parties other than the accused which occurred at the time of the event giving rise to the sex crime charged.

         These exceptions reflect a determination that, despite the general prohibition against evidence of past sexual behavior, certain evidence relating to sexual behavior may be appropriate for the fact-finder to consider in ascertaining the truth and securing a just determination in a case involving an alleged sex crime. See I.R.E. 102. The exception set forth in I.R.E. 412(b)(1)(C) was added in 1987 along with exception (D). The minutes of the Evidence Rules Committee meeting associated with the amendment indicate that the exceptions were based on the Model Rule. The "Model Rule" referenced in the committee minutes presumably refers to the Uniform Rules of Evidence, which were originally produced by the Uniform Law Commission in 1974.[5] Uniform Rule 412, on which the amendment appears to be based, was added in 1986 (the year before I.R.E. 412 was amended). Uniform Rule 412 (1986) was titled "Sexual Behavior" and reads:

(a) When inadmissible. In a criminal case in which a person is accused of a sexual offense against another person, the following is not admissible:
(1) Reputation or opinion. Evidence of reputation or opinion regarding other sexual behavior of a victim of the ...

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