State v. Chambers
| Decision Date | 05 June 2020 |
| Docket Number | Docket No. 47309 |
| Court | Idaho Supreme Court |
| Parties | STATE of Idaho, Plaintiff-Respondent, v. Steven Michael CHAMBERS, Defendant-Appellant. |
Eric D. Fredericksen, State Appellate Public Defender, Boise, for appellant Steven Michael Chambers. Erik R. Lehtinen argued.
Lawrence G. Wasden, Idaho Attorney General, Boise, for respondent State of Idaho. Mark W. Olson argued.
Steven Chambers appeals from a judgment of conviction entered upon his Alford plea to battery with intent to commit a serious felony. Chambers was initially charged with forcible rape against a young woman (who will be referred to by the initials N.S.). Pursuant to I.R.E. 412, Chambers moved to introduce evidence of a purportedly false allegation N.S. made against a different individual approximately six months after her alleged rape by Chambers. The State objected to the admission of such evidence. After a Rule 412 hearing, the district court excluded evidence of the purportedly false allegation.
The Idaho Court of Appeals heard Chambers’ appeal and held that false allegations made after the charged conduct could be admissible. However, the appellate court concluded that Chambers had failed to prove falsity at the Rule 412 hearing. Chambers filed a petition for review, which this Court granted.
For the reasons set out, we vacate Chambers’ judgment of conviction and remand the case for proceedings consistent with this opinion.
On June 3, 2016, a detective with the Coeur d'Alene Police Department responded to a 911 call regarding an allegation of rape. The alleged victim, N.S.,1 had called 911 reporting that Chambers had punched her in the stomach and then raped her. N.S. explained that she had met Chambers the day before. The two exchanged phone numbers and communicated by phone throughout the remainder of the day and late into the night. Those communications included sexually suggestive photographs and messages sent by both N.S. and Chambers. In the early morning, around 1:00 or 2:00 a.m., N.S. went to Chambers’ residence. After being at the residence for some time, N.S. alleged that Chambers had forced her onto his bed, removed her clothes, and forcibly raped her. After the alleged rape, N.S. claimed she escaped through the front door and called 911. After calling 911, N.S. deleted all of the messages she had exchanged with Chambers.
A detective interviewed Chambers at the police station. During this interview, Chambers told the detective that he was born addicted to drugs, did not learn to speak until he was twelve or thirteen years old, and that he suffered from a speech impediment. During the interview, Chambers admitted to having sexual intercourse with N.S., but insisted that it was consensual. However, later in the interview, Chambers admitted to punching N.S. in the stomach and forcing himself on her.2
The State charged Chambers with forcible rape under Idaho Code section 18-6101(4). Chambers filed a motion to introduce evidence regarding N.S.’s past sexual behavior pursuant to I.R.E. 412 (2017).3 Specifically, Chambers intended to introduce evidence that N.S. had made a false allegation of rape against another individual. In response, the State filed a motion in limine to exclude this evidence.
The purportedly false allegation made by N.S. that Chambers sought to admit occurred in December 2016, six months after Chambers allegedly raped N.S. In that case, N.S. called 911 to report that a man (who will be referred to by the initials K.C.) had raped her at his residence. This accusation presented similar facts to the case now on appeal. N.S. alleged that each man had pushed her onto a bed, pulled her clothing down, and forced himself upon her. In both cases, N.S. deleted all text messages between the accused and herself before calling the police. Also in both cases, the men insisted that the sexual intercourse had been consensual.4
K.C. was cooperative with authorities and passed a polygraph test in which he denied raping N.S. Based on the detective's encounter with both N.S. and K.C., the detective declined to arrest K.C. There is no evidence in the record to suggest that there was ever an arrest made or charges filed against K.C. based on the allegation made by N.S.
The district court held a Rule 412 hearing on June 12, 2017. Following arguments by the parties, the district court concluded that the evidence was not admissible pursuant to I.R.E. 412. The district court ruled that the allegation made in December was not admissible under the exception in I.R.E. 412 for "false allegations of sex crimes made at an earlier time" because the allegation against K.C. occurred six months after the allegation made against Chambers. Alternatively, the district court ruled that even if the evidence were allowed under Rule 412, the probative value of the evidence "is far outweighed by considerations of confusion of the issues, unfair prejudice, in the sense that we have another possibility of another mini trial within the case, and it has the definite risk of misleading the jury as far as focusing on the charge against the defendant."
Chambers entered into a conditional Alford5 plea to an amended charge of felony battery with the intent to commit a serious felony. Chambers reserved his right to appeal the district court's ruling regarding N.S.’s prior false allegation. The district court sentenced Chambers to a unified sentence of ten years, with two years fixed. However, the district court suspended the sentence and placed Chambers on supervised probation for three years.
Chambers timely appealed from his judgment of conviction. The Idaho Court of Appeals heard his appeal. State v. Chambers, No. 45608, 2019 WL 1891005 (Ct. App. Apr. 29, 2019). The Court of Appeals held that "the district court erred in interpreting I.R.E. 412(b) ([2])(C) to include a temporal requirement precluding purportedly false allegations made after the charged conduct." Id. at *4. However, the Court of Appeals affirmed the judgment of conviction because it found that Chambers had failed to prove that the allegation made against K.C. had been false at the I.R.E. 412 hearing. Id. at *7. Finally, the Court of Appeals rejected Chambers’ argument that his Sixth Amendment right to present a defense was violated by the exclusion of the evidence. Id. at *8-9. Chambers filed a petition for review with this Court, which we granted.
"When reviewing a case on petition for review from the Court of Appeals this Court gives due consideration to the decision reached by the Court of Appeals, but directly reviews the decision of the trial court." State v. Jeske , 164 Idaho 862, 867, 436 P.3d 683, 688 (2019) (quoting State v. Schmierer, 159 Idaho 768, 770, 367 P.3d 163, 165 (2016) ).
"[T]he interpretation of a rule of evidence, like the interpretation of a statute, is reviewed de novo." State v. Hill , 161 Idaho 444, 447, 387 P.3d 112, 115 (2016) (alteration in original) (quoting State v. Moore , 131 Idaho 814, 821, 965 P.2d 174, 181 (1998) ).
"When reviewing the trial court's evidentiary rulings, this Court applies an abuse of discretion standard." Jeske , 164 Idaho at 867, 436 P.3d at 688 (citing State v. Anderson , 162 Idaho 610, 614, 402 P.3d 1063, 1067 (2017) ).
When reviewing a lower court's decision for an abuse of discretion, this Court must analyze "whether the trial court: (1) correctly perceived the issue as one of discretion; (2) acted within the outer boundaries of its discretion; (3) acted consistently with the legal standards applicable to the specific choices available to it; and (4) reached its decision by the exercise of reason."
State v. Bodenbach, 165 Idaho 577, 591, 448 P.3d 1005, 1019 (2019) (quoting Lunneborg v. My Fun Life, 163 Idaho 856, 863, 421 P.3d 187, 194 (2018) ).
On appeal, Chambers argues that the district court abused its discretion by misinterpreting and misapplying Rule 412. Specifically, Chambers alleges that the district court erred when it: (1) determined that the purportedly false allegation must have been made prior to the charged offense; (2) concluded that the evidence was unfairly prejudicial; and (3) failed to consider the effect of the exclusion of the evidence on Chambers’ Sixth Amendment right to present a defense.6
Generally, evidence of a sex crime victim's past sexual behavior is not admissible in a criminal case. I.R.E. 412(a)-(b). This rule and others like it are commonly known as "rape shield" laws. The purpose of these laws is two-fold: First, "[t]he rule aims to safeguard the alleged victim against the invasion of privacy, potential embarrassment and sexual stereotyping that is associated with public disclosure" of the victim's prior sexual behavior. Fed. R. Evid. 412 advisory committee's note to 1994 amendment. Second, these laws encourage "victims of sexual misconduct to institute and to participate in legal proceedings against alleged offenders." Id.
However, the rule also provides a defendant in a criminal case with the ability to introduce evidence when that evidence is potentially relevant to the charged offense. See I.R.E. 412(b). I.R.E. 412(b) identifies circumstances in which specific instances of the victim's past sexual behavior may be admitted. Id. Those exceptions, which existed at the time this case arose, are as follows:
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