Robert Dennis v. Kevin Mazza

Summary

The Sixth Circuit affirmed denial of habeas relief, holding that the Kentucky Supreme Court's application of the state's "demonstrably false" standard to exclude evidence of the victim's prior unsubstantiated sexual abuse allegation did not unreasonably apply clearly established Confrontation Clause law under AEDPA. The court rejected the procedural default finding because the state court addressed the constitutional claim on the merits, and it upheld the state's rape-shield balancing test as not arbitrary or disproportionate under *Michigan v. Lucas*. Key topics: Confrontation Clause, rape-shield law, prior false allegations, "demonstrably false" standard, AEDPA deference, and procedural default.

Questions Presented

1. Whether the exclusion of evidence of S.J.'s prior false allegation violated Dennis's Sixth Amendment Confrontation Clause rights.