Summary
The Delaware Supreme Court affirmed the Superior Court’s judgment convicting Isaac Johnson of rape, sexual abuse of a child, and unlawful sexual contact. On appeal, Johnson argued that the trial court improperly excluded his testimony regarding the victim’s mother’s alleged infidelity, claiming it was relevant to show a motive for false allegations. The Supreme Court held that the evidence was irrelevant under Rule 401 and that its exclusion did not violate Johnson’s Sixth Amendment right to present a complete defense. Consequently, the conviction and sentence were upheld.
Topics
Practice areas
Questions Presented
- Whether the Superior Court abused its discretion in excluding Johnson’s testimony about Smith’s sexual behavior under the Sixth Amendment right to present a defense.
- Whether any error in excluding the testimony was harmless.
Holdings
- The Superior Court did not abuse its discretion; the excluded testimony was irrelevant and inadmissible under Rule 401 and therefore its exclusion did not violate the Sixth Amendment.
- Any error, if any, was harmless because the excluded testimony was not material to the State’s case.
Key quotations
““the right to present the defendant’s version of the facts . . . to the jury so it may decide where the truth lies.”” (at 11)
Factual background
Isaac Johnson lived with his girlfriend Marie Smith and her daughter L.F. in Smith’s home. Johnson was accused of raping L.F. and other sexual offenses. At trial, the State moved to exclude Johnson’s testimony about Smith’s sexual behavior, which the trial court sustained. Johnson appealed the evidentiary ruling.
Procedural history
The Superior Court convicted Johnson of rape, sexual abuse of a child, and unlawful sexual contact and sentenced him to 63 years. Johnson appealed, arguing the trial court erred by excluding testimony about the victim’s mother’s sexual behavior, claiming a Sixth Amendment violation.