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defendantappealtrialmotionprosecutor
defendantappealmotionwillprosecutor

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People v. Arenda, 416 Mich. 1, 330 N.W.2d 814

Facts

The charges against the defendant arose from incidents involving an eight-year-old boy. The prosecutor filed a motion in limine to exclude any evidence of sexual conduct between the victim and any person other than the defendant, citing the rape-shield law. The trial judge granted the motion, which led to the defendant's conviction. The defendant argued that evidence of the victim's sexual conduct was relevant to explain the witness's ability to describe the alleged sexual acts.

The charges against defendant arose out of incidents involving an eight-year-old boy. The prosecutor filed a motion in limine, based on the rape-shield law, to prohibit the admission of any evidence of sexual conduct between the victim and any person other than defendant.

Issue

Did the rape-shield law infringe upon the defendant's Sixth Amendment right of confrontation by prohibiting the admission of evidence regarding the victim's sexual conduct with others?

Defendant contends that these statutory prohibitions infringe upon his Sixth Amendment right of confrontation, see Davis v. Alaska, 415 U.S. 308, 94 S.Ct. 1105, 39 L.Ed.2d 347 (1974); Chambers v. Mississippi, 410 U.S. 284, 93 S.Ct. 1038, 35 L.Ed.2d 297 (1973).

Rule

M.C.L. § 750.520j; M.S.A. § 28.788(10) prohibits the admission of evidence of specific instances of the victim's sexual conduct unless it is material to a fact at issue and its prejudicial nature does not outweigh its probative value.

M.C.L. § 750.520j; M.S.A. § 28.788(10) provides: 'Evidence of specific instances of the victim's sexual conduct, opinion evidence of the victim's sexual conduct, and reputation evidence of the victim's sexual conduct shall not be admitted under sections 520b to 520g unless and only to the extent that the judge finds that the following proposed evidence is material to a fact at issue in the case and that its inflammatory or prejudicial nature does not outweigh its probative value.'

Analysis

The court determined that the rape-shield law's prohibitions did not significantly diminish the defendant's right of confrontation. The court noted that the defendant was allowed to cross-examine the victim about possible sources of knowledge regarding sexual conduct, and the trial judge's ruling was based on the absence of an offer of proof showing relevant evidence. The court concluded that the excluded evidence was not material to the case.

Therefore, we are persuaded that the prohibitions in the rape-shield law will not deny a defendant's right of confrontation in the overwhelming majority of cases and, in particular, not in this case.

Conclusion

The Supreme Court reversed the decision of the Court of Appeals and reinstated the defendant's conviction, finding no error in the trial that required reversal.

Therefore, we reverse the decision of the Court of Appeals and reinstate defendant's conviction.

Who won?

The People prevailed in the case, as the Supreme Court upheld the conviction, finding that the rape-shield law did not violate the defendant's rights.

The People prevailed in the case, as the Supreme Court upheld the conviction, finding that the rape-shield law did not violate the defendant's rights.

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