State v. Jeffries
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The Supreme Court affirmed the judgment of the court of appeals upholding Defendant's convictions of four counts related to two specific instances of sexual abuse of D.S., holding that the trial court and court of appeals correctly applied Ohio's rape-shield law and determined that evidence of D.S.'s prior nonconsensual sexual assault was inadmissible.
On appeal, Defendant asserted that the trial court erred in prohibiting him from introducing evidence during trial that D.S. had previously been sexually assaulted by another person, arguing that the rape-shield law applies only to an accuser's prior consensual sexual activity. The lower court held that Ohio's rape-shield law addresses all sexual activity, not only consensual sexual activity. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the plain meaning of the term "sexual activity" as used in the rape-shield law includes both consensual and nonconsensual sexual activity; and (2) therefore, all sexual activity is barred from admission into evidence by the rape-shield, absent certain exceptions listed in the law.
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