State of Louisiana v. James H. Dudley

Summary

The Louisiana Court of Appeal, First Circuit, granted the State's supervisory writ and held that a “hookup text” was inadmissible at trial for cross-examining the victim under the rape shield statute. The court stated that the defendant's right to present a defense does not require admission of irrelevant evidence or evidence with minimal probative value, while noting that the State conceded admissibility of a separate 2:16 a.m. text.

Holdings

1. The district court abused its discretion by ruling that the hookup text was admissible at trial for purposes of cross-examining the victim.
2. Because the State conceded the admissibility of the 2:16 a.m. text, the defendant was not barred from arguing or eliciting testimony that A.B. had sex with the defendant while believing him to be C.T.D.

Questions Presented

1. Whether the district court abused its discretion by ruling that the hookup text was admissible at trial for purposes of cross-examining the victim.
2. Whether the defendant's right to present a defense required admission of the text despite the rape shield statute and the text's limited probative value.

Disposition

writ_granted