State v. Williams

Summary

The Louisiana Supreme Court addresses whether Louisiana's rape shield law bars evidence concerning the victim's sexual relationship with the defendant's teenage son in an aggravated rape prosecution. The court holds that such evidence is generally barred if the state does not rely on DNA evidence concerning the aborted fetus, but that the defendant may challenge the DNA evidence and raise reasonable doubts about its validity if the state presents it at trial.

Holdings

1. If the State elects not to present DNA evidence concerning the aborted fetus, La. C.E. art. 412 bars evidence offered to show that the defendant's teenage son had a sexual relationship with the victim during the charged time period and was the likely father of the fetus.
2. If the State introduces DNA evidence indicating a high probability that Williams fathered the aborted fetus, La. C.E. art. 412 cannot preclude the defense from raising reasonable doubts about the validity of the DNA results, even if the challenge tends to show that the fetus resulted from the victim's sexual behavior with another person.
3. The court expressed no opinion on whether the defendant could present other evidence of specific instances of the victim's prior sexual behavior under the exception for evidence showing another person was the source of semen or injury, because the defendant's notice did not include an accompanying statement identifying that evidence.

Questions Presented

1. Whether Louisiana's rape-shield statute bars evidence that the defendant's teenage son had a sexual relationship with the victim and may have fathered the aborted fetus when the State does not introduce evidence concerning the fetus's paternity.
2. Whether the statute may bar the defense from challenging DNA evidence introduced by the State to establish that the defendant fathered the aborted fetus, even if the challenge tends to show that another person engaged in sexual conduct with the victim.

Disposition

other