Rhodes v. Dittmann

Dist. Ct. erred in denying defendant’s habeas petition challenging his first-degree murder conviction on ground that trial court denied him his Sixth Amendment right to confront witnesses against him, when it limited his cross-examination of key govt. witness, who presented evidence on State’s motive theory that defendant had killed victim based on belief that victim had beaten defendant’s sister on prior day. Record showed that prosecution had presented graphic photographic evidence of sister’s injuries, and trial court precluded defendant from eliciting from sister fact that sister had experienced other beatings from victim without reprisal from defendant. State court could not reasonably have found that defendant’s rebuttal evidence could have confused jury, and instant preclusion of defendant’s proffered evidence was unfair, where said proposed evidence was relevant on instant motive theory and was “prejudicial” only with respect to state’s view of case. Fact that defendant testified on domestic violence issue did not require different result, and Dist. Ct.’s belief that instant preclusion was harmless error was not supported by record, where: (1) jury was presented with lopsided presentation of evidence on motive theory; and (2) strength of state’s case against defendant was not clear-cut, since eyewitness testimony identifying defendant as culprit had weaknesses.