Brief Fact Summary. Elizabeth Berman (Victim) accused Roger Boggs (Petitioner-Appellee) of sexually assaulting her one Christmas Eve. At trial, Petitioner-Appellee attempted to cross-examine Victim concerning prior accusations she made that allegedly turned out to be false, and was disallowed from doing so. Petitioner-Appellee, while incarcerated, sought a writ of habeas corpus, which was granted by the lower court, and Terry Collins (Respondent-Appellant), the Warden of the Warren Correctional Institute where Boggs was imprisoned, appeals here.
Synopsis of Rule of Law. A defendant is not denied a right to a full and meaningful defense, as supplied by the United States Constitution’s Confrontation Clause, by being prohibited on cross-examination from inquiring into prior false accusations made by the alleged victim, when the evidence is offered to attack the alleged victim’s general credibility.
While mental illness can indeed be relevant to a witness's credibility, courts hold that the decision of whether or not to allow in evidence of a witness's mental illness falls within the broad discretion of trial courts as they balance possible prejudice versus probative value.View Full Point of Law
Issue. Was it error for the lower court to disallow Petitioner-Appellee from inquiring into Victim’s past false allegations of rape through a cross-examination of Victim, and to further disallow Petitioner-Appellee to introduce testimony of two witnesses concerning Victim’s past false allegations?
Held. No; the testimony would have been an attack on the witness’s general credibility and when offered for such a use, the admissibility of the evidence is not guaranteed by the Confrontation Clause.
Discussion. The court cites past precedent and the, “vital role cross-examination can play in casting doubt on a witness’s credibility.” However, the court goes on to state, again citing past precedent, that, “not all conceivable methods of undermining credibility are constitutionally guaranteed.” Specifically, the court writes:
No matter how central an accuser’s credibility is to a case–indeed, her credibility will almost always be the cornerstone of a rape or sexual assault case, even if there is physical evidence–the Constitution does not require that a defendant be given the opportunity to wage a general attack on credibility by pointing to individual instances of past conduct.
As there is no absolute Constitutional right to impeach the general credibility of a witness, Petitioner-Appellee does not have a valid Confrontation Clause claim.