## Facts

- Nathaniel M. Lewis and Christina Heaslet, University of Akron students who knew each other socially, had sexual intercourse in Heaslet’s dorm room after spending time together.
- Heaslet reported the intercourse as forcible and nonconsensual; Lewis maintained it was consensual.
- Before trial, Lewis anonymously received photocopied excerpts from Heaslet’s diary containing statements about her feelings regarding the prosecution and her sexual self-description.
- Lewis sought to use diary excerpts to impeach Heaslet’s credibility and support defenses of consent and fabrication/motive.
- Applying Ohio’s rape shield statute, the trial court admitted only limited excerpts (including statements reflecting ambivalence about “trying to get Nate locked up,” describing Lewis as a “player,” and suggesting she “needed some drama”) and excluded other passages explicitly describing her sexual behavior and difficulty saying no.
- A jury convicted Lewis of rape, and he received an eight-year sentence.
- After state appellate review and denial of further review in the state supreme court, Lewis sought federal habeas relief under 28 U.S.C. § 2254; the district court denied relief.

## Issues

1. Whether excluding diary passages under Ohio’s rape shield statute violated the Sixth Amendment Confrontation Clause by materially restricting cross-examination relevant to consent and the complainant’s motive to accuse.
2. Whether, under 28 U.S.C. § 2254(d), the state-court approval of the exclusion was contrary to, or an unreasonable application of, clearly established Supreme Court Confrontation Clause law.

## Decision

- The Sixth Circuit reversed the district court’s denial of habeas relief.
- The court held the exclusion of the contested diary excerpts violated the Confrontation Clause.
- The court concluded the excluded passages were probative of both consent and possible motive to pursue charges and would have provided the jury a materially different basis to assess credibility.
- The court determined the state-court outcome reflected an unreasonable application of clearly established federal law governing the right to effective cross-examination.

## Legal Principles

- The Sixth Amendment guarantees an opportunity for effective cross-examination, including inquiry exposing bias, motive, or ulterior reasons for testimony.
- Rape shield statutes serve legitimate interests but cannot be applied to bar otherwise relevant evidence when exclusion would infringe confrontation rights, particularly where evidence bears directly on consent or motive to fabricate.
- Trial courts may impose reasonable limits on cross-examination to prevent harassment, prejudice, confusion, or marginally relevant inquiry, but they may not exclude probative impeachment such that the jury lacks a materially different impression of a key witness’s credibility.
- Under AEDPA, federal habeas relief is available when the state court’s adjudication is contrary to, or an unreasonable application of, clearly established Supreme Court precedent, or rests on an unreasonable factual determination.

## Conclusion

The Sixth Circuit held that, in a credibility-driven rape prosecution, excluding diary excerpts that directly supported consent and motive theories unconstitutionally restricted cross-examination; because the state courts upheld that restriction, habeas relief was warranted under AEDPA.


Lewis v. Wilkinson, 307 F.3d 413 (6th Cir. 2002)