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Government of the Virgin Islands v. Scuito

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Brief Fact Summary. Defendant Scuito was convicted for forcible rape and appeals the trial Judge’s denial of his motion for a psychiatric examination of the complainant.

Synopsis of Rule of Law. The purpose of Federal Rule of Evidence Rule 412, which excludes evidence of the prior sexual history of alleged rape victims, is to protect alleged victims from “degrading and embarrassing disclosure of intimate details of their private lives”.

Points of Law - Legal Principles in this Case for Law Students.

Indeed, we have observed that:a psychiatric examination may seriously impinge on a witness right to privacy; the trauma that attends the role of complainant to sex offense charges is sharply increased by the indignity of a psychiatric examination; the examination itself could serve as a tool of harassment; and the impact of all these considerations may well deter the victim of such a crime from lodging any complaint at all.

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Facts. Defendant was charged with forcible rape and at trial the only issue was whether Defendant the complainant consented. Before trial, Defendant moved for a psychiatric examination of the complainant to show that she fantasizes to extremes and abuses controlled substances. The trial judge denied the motion and Defendant was convicted. Defendant appeals, arguing that the trial judge abused his discretion by denying the motion.

Issue. Did the trail judge abuse or fail to exercise his discretion by denying Defendant’s motion for a psychiatric exam of the complainant?

Held. No. Judgment affirmed.
The Court based its decision on Rule 412 which excludes evidence of the prior sexual history of alleged rape victims. While Rule 412 does not by its language literally apply to psychiatric examinations, the court holds that based on the spirit of the rule, which serves to protect alleged rape victims from having to disclose intimate details of their private lives, the trial judge did not abuse or fail to exercise his discretion. A psychiatric evaluation may force the complainant to reveal such intimate details.

Discussion. The Court uses the “Rape Shield Law”, Rule 412, to justify the denial of a motion for a psychiatric evaluation of the complainant, illustrating how far a court is willing to take the Rape Shield

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