Olden v. Kentucky

James Olden (defendant) and Starla Matthews met in a bar; the two eventually left the bar and had sexual intercourse. Olden claimed that the intercourse was consensual, but Matthews claimed that she had been kidnapped, raped, and forcibly sodomized. Olden was indicted for kidnapping, rape, and forcible sodomy. At Olden's trial, Olden sought to show that Matthews had a motive to lie about the incident because she was seeing Olden’s half-brother, Bill Russell, and she feared that a revelation of the incident would ruin the relationship. To prove this, Olden tried to introduce evidence that Matthews was living with Russell at the time of trial. The trial court excluded the evidence on the grounds that Matthews, a white woman, having a relationship with Russell, a black man, could unfairly prejudice Matthews in the eyes of the jury. Similarly, the trial court also sustained an objection when the defense tried to cross-examine Matthews about her living situation. The jury acquitted Olden of kidnapping and rape but convicted him of forcible sodomy. Olden appealed, asserting that the trial court's refusal to allow him to impeach Matthews's testimony by introducing evidence of her possible motive to lie violated his rights under the Confrontation Clause of the Sixth Amendment. The Kentucky Court of Appeals affirmed the conviction, and Olden petitioned the United States Supreme Court for certiorari.