Michigan v. Lucas

Background

Nolan Lucas was tried in Michigan for sexual assault. He did not file the written motion and offer of proof required by Michigan’s rape‑shield law within 10 days after arraignment. At trial the judge refused to allow Lucas to present evidence of a prior sexual relationship with the alleged victim, and Lucas was convicted. The Michigan Court of Appeals reversed, saying precluding such evidence always violates a defendant’s Sixth Amendment rights.

Reasoning

The Supreme Court considered whether the Court of Appeals’ automatic, or per se, rule was correct. The Court said states have legitimate interests in protecting rape victims from surprise and harassment and that notice rules can help prosecutors investigate and judges to weigh whether evidence is more prejudicial than useful. Relying on prior decisions, the Court explained that precluding evidence can sometimes be an appropriate sanction for failing to follow valid procedural rules, so a blanket ban was wrong. The Court did not decide whether preclusion was proper on these facts.

Real world impact

The decision sends the question back to Michigan courts to decide whether the statute authorizes preclusion and whether preclusion was justified in Lucas’s trial. Defendants who miss strict notice deadlines may now face the real risk that evidence will be barred in some cases. The ruling also upholds the idea that states can protect victims’ privacy while still allowing defendants to challenge exclusions in individual cases.

Dissents or concurrances

Justice Blackmun agreed that preclusion can sometimes be justified to protect victims and reduce delay. Justice Stevens (joined by Justice Marshall) dissented, arguing the state court’s judgment should have been left intact because the notice rule here was unreasonably short.