St. John v. State of North Carolina Parole Commission
United States District Court for the Western District of North Carolina
764 F. Supp. 403 (1991)
- Written by Katrina Sumner, JD
Facts
Jim St. John (defendant) was tried in a state court for selling obscene videos. St. John had attempted to introduce expert evidence in the form of a study that involved focus groups viewing the films for which St. John was indicted. Twenty to 24 people viewed the videos in conditions that were under St. John’s exclusive control. The record raised concerns regarding whether the study’s participants were average community members. The trial judge excluded the study, believing that the study would not aid the 12 members of the jury in determining whether the videos were obscene. St. John was convicted and given a sentence of six years of incarceration. After St. John had exhausted his appeals at the state level, he filed a habeas petition in federal court. St. John argued that the trial court had violated his Sixth Amendment right to confront witnesses and his Fourteenth Amendment right to due process because the court had excluded expert evidence. The State of North Carolina Parole Commission, in whose custody St. John remained, filed a motion for summary judgment.
Rule of Law
Issue
Holding and Reasoning (Porter, J.)
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