This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
- The case involves two altercations between the Defendant and his girlfriend (Victim) over three weeks, leading to charges of aggravated battery against a household member. In the first incident, the Defendant claimed self-defense, and in the second, he argued that the Victim injured herself in retaliation for him ending their relationship (para 2).
Procedural History
- [Not applicable or not found]
Parties' Submissions
- Defendant: Argued that the district court erred by excluding other acts evidence about the Victim, which he proffered to demonstrate her motive to falsely accuse him. He also contended that the court improperly restricted his ability to cross-examine the Victim about her prior felony conviction and claimed his trial counsel was ineffective (para 1).
- State: Moved to exclude witnesses who could testify about the Victim's past behavior, arguing that such evidence was merely propensity evidence and not relevant to intent or motive (para 3).
Legal Issues
- Whether the district court erred by excluding testimony regarding the Victim's past behavior as impermissible propensity evidence under Rule 11-404(B).
- Whether the district court erred by not allowing the Defendant to question the Victim about the nature of her prior felony conviction.
- Whether the Defendant received ineffective assistance of counsel due to the failure to present corroborating evidence (paras 5, 12, 17).
Disposition
- The court affirmed the convictions for aggravated battery against a household member, rejecting the Defendant's arguments regarding the exclusion of other acts evidence, the restriction on cross-examination about the Victim's prior felony conviction, and the claim of ineffective assistance of counsel (paras 1, 11, 16, 20).
Reasons
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The court held that the district court did not abuse its discretion in excluding evidence of the Victim's past behavior, as it constituted impermissible propensity evidence under Rule 11-404(B). The court found no abuse of discretion in the decision to prevent the Defendant from delving into the specifics of the Victim's prior felony conviction, as it would not have added significant probative value on the issue of credibility beyond the fact of the conviction itself. Additionally, the court concluded that the Defendant failed to establish a prima facie case of ineffective assistance of counsel, noting the lack of evidence in the record to support the claim that additional corroborating evidence was likely available and would have been favorable to the Defendant's defense (paras 6, 14, 19).
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