Lewis v. Wilkinson

307 F.3d 413 (2002)

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Lewis v. Wilkinson

United States Court of Appeals for the Sixth Circuit
307 F.3d 413 (2002)

  • Written by Sharon Feldman, JD

Facts

Nathaniel Lewis (defendant) and Christina Heaslet became friends in college. One night, Heaslet invited Lewis to her room. According to Lewis, he and Heaslet engaged in consensual sex. Heaslet maintained that she was raped. Lewis was indicted for rape. Before trial, someone anonymously sent Lewis photocopied excerpts from Heaslet’s diary. Lewis wanted to cross-examine Heaslet on excerpts relevant to Heaslet’s consent and motive to lie. The court permitted Lewis to introduce Heaslet’s statements that she felt guilty “for trying to get Nate locked up, but his lack of respect for women is terrible,” she thought she “pounced on Nate because he was the last straw” and she always “seemed to need some drama” in her life, and she was “sick of men taking advantage” of her. However, relying on Ohio’s rape-shield law, the court prohibited Lewis from introducing the rest of the excerpt in which Heaslet wrote that she was sick of herself for “giving into them,” she was “not a nympho like all those guys think” and was “just not strong enough to say no to them,” she was “tired of being a whore,” and this was “where it ends.” Lewis was convicted. The court of appeals affirmed, the Ohio Supreme Court denied leave to appeal, and the district court denied Lewis’s habeas corpus petition. Lewis appealed.

Rule of Law

Issue

Holding and Reasoning (Steeh, J.)

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