Idaho v. ChambersAnnotate this Case
Steven Chambers appealed his conviction entered upon his "Alford" plea to battery with intent to commit a serious felony. Chambers was initially charged with forcible rape against a young woman. Pursuant to I.R.E. 412, Chambers moved to introduce evidence of a purportedly false allegation "N.S." made against a different individual approximately six months after her alleged rape by Chambers. The State objected to the admission of such evidence. After a Rule 412 hearing, the district court excluded evidence of the purportedly false allegation. The Idaho Court of Appeals heard Chambers’ appeal and held that false allegations made after the charged conduct could be admissible. However, the appellate court concluded that Chambers had failed to prove falsity at the Rule 412 hearing. After its review, the Idaho Supreme Court concluded the district court erred when it determined that Rule 412 contained a temporal requirement that the false allegation must precede the events giving rise to the charge. Further, the district court abused its discretion by applying the wrong balancing test. The Supreme Court announced guidelines and procedure for the district court to use on remand to determine whether evidence of the purportedly false allegation was admissible. Judgment of conviction was vacated and the matter remanded for further proceedings.