United States v. Stamper

Dewayne Stamper (defendant) was federally charged with statutory rape. The sole evidence incriminating Stamper at trial would have been the 12-year-old complainant’s testimony. Before trial began, Stamper moved to introduce evidence that the complainant had previously fabricated sexual-abuse allegations against three other men. The district court appointed an attorney to represent the complainant’s interests and held an in camera hearing at which the government (plaintiff), the complainant, and Stamper could examine Stamper’s witnesses. The in camera hearing revealed that in early 1989, the complainant was living with her mother, Maxine Beck, and her mother’s boyfriend, Reuben Teesataskie, and that conflicts arose between the complainant and Maxine and Teesataskie. The complainant then alleged that Teesataskie, her uncle, and her 14-year-old cousin all had sexually fondled her (the prior-sexual-abuse allegations). The complainant moved to her father Jack Beck’s house to live separately from Teesataskie. At least a year later, Jack threatened to punish the complainant for repeatedly sneaking out of Jack’s house at night to meet a boy. Soon after, the complainant alleged that Stamper, Jack’s 20-year-old coworker and friend, had had sex with the complainant twice in July 1990. After the allegation against Stamper, the complainant voluntarily moved back to Maxine and Teesataskie’s home. Law enforcement dropped the charges against the first three men after the complainant admitted that she had lied about the prior-sexual-abuse allegations. However, by the time of Stamper’s trial, the complainant was again claiming that the prior allegations were true. The issue before the district court was whether Stamper could introduce evidence of the prior-sexual-abuse allegations to support his argument that the complainant engaged in a pattern of fabrication to manipulate adults in her life.