Williams v. State

681 N.E.2d 195 (1997)

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Nature of the Case

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Facts

The victim was working as a topless dancer. She finished work at approximately 2:45 a.m., she walked out into the parking lot and asked two strangers, D and co-defendant Antoine Edmondson, for a ride home. The two men agreed and she got into the car. D did not drive the car directly to the victim's home. Instead, he told her that 'they had to make a stop.' He drove into an alley behind a different club where Edmondson exited the car. The victim then attempted to run away but Edmondson grabbed her arms and pulled her into the back seat of the car. D drove to a public park and stopped the car in a dark area of its parking lot. The two then ordered the victim to engage in sexual acts. Edmondson pulled a gun out of his pocket and placed it on the arm rest of the front seat. He then removed the victim's shoe and sock and pulled her right pants leg off. The victim managed to grab the gun, open the car door, and run away. She fired the gun behind her and, although she apparently had never fired a weapon before, shot Edmondson in the jaw. Williams and Edmondson were arrested. P sought to exclude evidence of the victim's sexual history pursuant to Indiana's Rape Shield Rule, Rule 412. D did not object to this motion. P sought to exclude evidence of the victim's history of drug use. D objected. The trial court granted both motions and excluded the evidence of both the victim's sexual history and her prior drug use. D was allowed to question the victim about drug use at the time of the incident. During the trial, the victim testified on cross-examination that she did not use cocaine on the day of the incident or the day of the trial. The trial court stood by its original decision to exclude the evidence. D made an offer of proof and the victim testified, outside the hearing of the jury, that she was previously addicted to cocaine and had received treatment. The jury found D guilty of one count of attempted deviate conduct and criminal confinement. The appellate court reversed the conviction because it held that the trial court should have admitted the evidence of the victim's sexual history and prior drug use. P appealed.