No. The court said that a victim's past should not be put on trial. A special law called a 'Rape Shield Rule' exists to protect victims from having their private history used against them. Just because someone may have had sex for money or used drugs before doesn't mean they automatically agreed to have sex this time. The court decided that the defendant's attempt to talk about the victim's past was exactly the kind of victim-blaming the law was designed to prevent. Her past drug use was also off-limits because there was no proof it actually affected her memory of the attack.

No, it wasn’t wrong. The court said that talking about the woman’s past wasn’t needed to figure out what happened that night. They wanted to make sure the trial was fair and didn’t unfairly judge the woman based on her past. This follows rules that help protect people’s privacy and ensure fair trials.

Yes. Indiana's Rape Shield Rule, Evidence Rule 412, prohibits the admission of such evidence because a victim's past sexual conduct with third parties is not relevant to the issue of consent on a particular occasion. The court reasoned that Rule 412 was specifically enacted to prevent a victim from being put on trial and to preclude a generalized inquiry into their sexual history to imply consent. The exceptions to Rule 412, such as prior sexual history with the defendant, did not apply here. The court explicitly rejected the notion that a victim's alleged history of prostitution creates an exception, stating it is 'intolerable to suggest that because the victim is a prostitute, she automatically is assumed to have consented with anyone at any time.' Regarding prior drug use, the court held it was irrelevant to credibility unless there was a specific showing that it impaired the victim's capacity to perceive or remember the events, which was not established. The court concluded that allowing this evidence would undermine the core purpose of the Rape Shield Rule and that its exclusion did not violate the defendant's Sixth Amendment rights.

No. The trial court did not err because the evidence of the victim's past drug use and sexual history was not directly relevant to the facts of the case. I maintain that such evidence is generally inadmissible to protect the victim's privacy and ensure a fair trial focused on the incident in question, not the victim's character or past behavior. This aligns with established precedents and the Rape Shield Rule, which restricts admissibility of past sexual conduct unless it directly pertains to the case. The exclusion of the victim's prior drug use was proper because it was not shown to substantially affect her current ability to perceive, remember, or testify. The jury had ample opportunity to assess the credibility of her testimony as defense counsel repeatedly challenged the accuracy of her memory. Regarding the victim's alleged past acts of prostitution, none of the exceptions to Rule 412's general prohibition of inquiry into the victim's sexual history apply here. The evidence offered was of the classic sort precluded by the Rape Shield Rule: purported incidents with other men at other times offered simply to show that the victim had consented in the past in the hope the inference will be drawn that she consented here. Rule 412 was enacted to prevent just this kind of generalized inquiry into the reputation or past sexual conduct of the victim in order to avoid embarrassing the victim and subjecting the victim to possible public denigration. The exclusion of this evidence does not violate the defendant's constitutional rights because it does not fall within any of the recognized exceptions where such evidence may be constitutionally required. The convictions are affirmed.

Williams v. State

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