Daniels v. State

In Daniels v. State, 767 P.2d 1163 (Alaska App. 1989), the State charged the defendant, Daniels, with sexual abuse of a minor in the first degree for sexually abusing his foster daughter. Daniels's defense was that his foster daughter had falsely accused him of the abuse. He wanted to present evidence that he and his wife had learned that the foster daughter had admitted to sexually molesting a five-year-old boy. Daniels and his wife decided that they did not want the foster daughter to remain in their home and told the foster daughter of their decision. Daniels's theory of defense was that in retaliation, the foster daughter accused Daniels of sexual abuse. The trial court limited Daniels's cross-examination of the foster daughter on this issue and precluded both Daniels and his wife from making any specific reference to their foster daughter's sexual abuse of another child. The jury convicted Daniels. On appeal, we concluded that the trial court, by limiting Daniels's defense, had denied Daniels the right to confront and cross-examine the witnesses against him and reversed his conviction. The Court held Daniels should have been allowed to develop his defense by cross-examining his foster daughter and presenting testimony about the issue through both his own and his wife's testimony.