Olden v. Kentucky
488 U.S. 227 (1988)

Facts:  V claimed that she was raped by D.  D argued that they had consensual sex and V was lying because she didn’t want to admit to this incident to her boyfriend, who testified for V.  V during trial claimed that she lived with her mother, but in fact, she lived with her boyfriend.  Defense wanted to show V’s motive for lying about this whole incident and present evidence that V (white) was living with her boyfriend (black).  Trial court excluded this evidence and D was sentenced for 10 years for forcible sodomy.  D claims that exclusion of this evidence violated his constitutional right to cross-examine his accuser.

Procedure:  The appellate court upheld the conviction by ruling that even though the evidence was relevant and didn’t violate the rape shield statute, but the prejudicial effects of this evidence outweighed its benefits.

Issue: Was D denied of his constitutional rights?

Holding: Yes 

Rationale:  The exposure of a witness’ motivation in testifying is a proper and important function of the constitutionally protected right to cross-examination.  In this case, it is clear that a reasonable jury could have doubted the credibility of V if it had know about the relationship between V and her boyfriend which could very well have provided V with the motive to falsely accuse D of rape.  While a trial court may impose reasonable limits on defense counsel’s inquiry into the potential bias of a prosecution witness, to take the witness’ safety, or interrogation that would be repetitive or only marginally relevant, speculation as to the effect of juror’s racial biases cannot justify exclusion of cross-examination with such strong potential to demonstrate the falsity of V’s testimony.