EvidenceRape shield lawRelevanceTrial court discretionIowa Rule of Evidence 412rape shieldabuse of discretionprobative value
Facts
The State introduced evidence that the complainant said "rape" shortly after the incident and later told a nurse that a man had raped her. In response, the defendant sought to introduce evidence that in 1984 the complainant had said "he raped me" after an unrelated consensual sexual encounter. The State moved in limine to exclude that evidence under Iowa Rule of Evidence 412. The trial court sustained the State's objection and excluded the evidence.
Issue
Did the trial court abuse its discretion in excluding the defendant's proffered evidence that the complainant had previously claimed rape after a consensual sexual encounter? More specifically, was the evidence sufficiently relevant to require admission notwithstanding the rape shield concerns raised by Rule 412?
Rule
Rulings on admissibility of evidence are discretionary and will be reversed only for abuse of discretion in balancing probative force against the danger of undue prejudice. Whether or not proffered evidence falls within the rape shield law, its admissibility turns on relevance: whether it makes a factual issue more or less believable. Under Rule 412, the trial court must weigh on a case-by-case basis whether evidence of a victim's prior sexual activity contributes more to truth-finding than it costs in harm to the victim's reputation and privacy.
See the holding & full analysis
Create a free KwikCourt account to unlock the rest of this brief — and practice the case.
The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case
One of 10 multiple-choice questions for this case. Pick an answer to see why.
In a sexual assault prosecution in Des Moines, Nolan Price seeks to introduce testimony that five years earlier the complainant, Tessa Moran, shouted that a former boyfriend had "assaulted" her after what another witness believed was consensual sex at a party. Tessa and the former boyfriend both deny that the prior episode ever happened.
If the trial judge excludes the testimony, which is the best assessment on appeal?
Explanation. The governing rule is discretionary balancing of relevance and prejudice. The majority held that whether the evidence is viewed inside or outside rape shield principles, admissibility turns on relevance and the trial court's case-specific balancing. Doubt about whether the prior incident occurred at all reduces probative value, and the judge may consider the rape shield purpose of keeping the focus on proof against the accused rather than the complainant's past conduct. Exclusion on these facts would not likely be an abuse of discretion.