## Facts

- Jim St. John was tried in North Carolina state court for selling allegedly obscene videos.
- At trial, St. John sought to introduce defense evidence in the form of a study using focus groups that viewed the same films for which he was indicted.
- Approximately 20 to 24 people viewed the videos, and the viewing conditions were under St. John’s exclusive control.
- The record raised concerns about whether the study participants were representative “average” members of the relevant community.
- The state trial judge excluded the study, reasoning that it would not help the 12 jurors decide whether the videos were obscene under community standards.
- St. John was convicted and sentenced to six years of incarceration.
- After exhausting state appellate review, St. John filed a federal habeas corpus petition under 28 U.S.C. § 2254 in the Western District of North Carolina.
- St. John claimed the exclusion of the study violated (1) the Sixth Amendment right to confront witnesses and (2) the Fourteenth Amendment right to due process.
- The State of North Carolina Parole Commission, in whose custody St. John remained, moved for summary judgment.

## Issues

1. In a § 2254 habeas proceeding, did the state trial court’s exclusion of St. John’s focus‑group study offered on community standards in an obscenity prosecution violate the Sixth Amendment Confrontation Clause or the Fourteenth Amendment Due Process Clause?

## Decision

- The court granted the Parole Commission’s motion for summary judgment.
- The court denied St. John’s petition for writ of habeas corpus.
- The court held that excluding the defense study did not violate the Confrontation Clause and did not deprive St. John of due process.

## Legal Principles

- Federal habeas relief does not lie for alleged state-law evidentiary errors unless the ruling amounts to a violation of the U.S. Constitution.
- The Confrontation Clause protects a defendant’s ability to confront and cross-examine adverse witnesses; it does not guarantee admission of a defendant’s preferred defense evidence.
- Due process is violated by exclusion of defense evidence only when the exclusion is so extreme that it renders the trial fundamentally unfair.
- In obscenity prosecutions applying “contemporary community standards,” jurors may assess the allegedly obscene materials themselves, and a trial court may exclude proposed studies when the court concludes they would not assist the jury or lack adequate reliability (including concerns about representativeness and the conditions under which the viewing occurred).
- On summary judgment in a habeas case, the respondent is entitled to judgment when the petition’s constitutional theories fail as a matter of law on the undisputed record.

## Conclusion

St. John’s habeas petition failed because the federal district court concluded that the state trial judge’s decision to exclude St. John’s focus‑group study—given concerns about the study’s setup and whether its participants reflected average community members—was not a constitutional violation: it did not implicate the Sixth Amendment’s confrontation protections and did not make the state trial fundamentally unfair under due process.


St. John v. State of North Carolina Parole Commission, 764 F. Supp. 403 (1991)