Smith's Criminal Case Compendium
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Nevada v. Jackson, 569 U.S. __, 133 S. Ct. 1990 (Jun. 3, 2013)
The Court reversed the Ninth Circuit, which had held that the defendant, who was convicted of rape and other crimes, was entitled to federal habeas relief because the Nevada Supreme Court unreasonably applied clearly established Supreme Court precedent regarding a criminal defendant’s constitutional right to present a defense. At his trial, the defendant unsuccessfully tried to introduce extrinsic evidence that the victim previously reported that the defendant had assaulted her but that the police had been unable to substantiate those allegations. The state supreme court held that this evidence was properly excluded. The Ninth Circuit granted habeas relief. The Court reversed, noting in part that it “has never held that the Confrontation Clause entitles a criminal defendant to introduce extrinsic evidence for impeachment purposes” (emphasis in original).