State v. Walker
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The Supreme Court affirmed Defendant’s conviction of two counts of incest and two counts of sexual assault, holding that the district court did not abuse its discretion when it excluded polygraph evidence or evidence pertaining to Defendant’s psychosexual profile and correctly applied Montana’s Rape Shield Law, Mont. Code Ann. 45-5-511(2), to exclude evidence of the victim’s alleged prior sexual conduct.
Specifically, the Court held that the district court (1) did not abuse its discretion in excluding Defendant’s polygraph evidence pursuant to Mont. R. Evid. 702, as there was no basis to depart from precedent that polygraph test results are inadmissible in Montana court proceedings; (2) did not abuse its discretion in excluding a defense expert’s testimony that Defendant’s psychosexual profile revealed no sexual interest in children where the testimony would have improperly bolstered Defendant’s claim of innocence; and (3) did not arbitrarily or mechanically apply the Rape Shield Law to exclude evidence.
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