## Facts

- A 17-year-old complainant traveled to Manhattan with friends and later encountered three teenage defendants while out alone near a car.
- The complainant testified defendants surrounded her, pressured her to enter a car, and implied she would be harmed if she did not comply.
- She testified that during a drive through Manhattan and Brooklyn she repeatedly asked to be let out but was refused, and she feared defendants were armed.
- The complainant testified she was taken to a basement apartment in Brooklyn where she was locked in and forcibly raped and sodomized by the defendants, and that an additional sexual act occurred afterward before she was released near a train station.
- She promptly reported the incident to police.
- Williams testified the complainant voluntarily accompanied them, appeared friendly and flirtatious, and that he believed she consented.
- At trial, defendants sought to introduce evidence of the complainant’s alleged prior group sexual activity; the court excluded it under CPL 60.42 after an in camera proffer.
- Defendants requested a jury instruction requiring acquittal if they honestly (and reasonably) believed the complainant consented; the trial court declined to give a separate mistake-of-fact-as-to-consent charge.

## Issues

1. Whether excluding evidence of the complainant’s alleged prior group sexual activity under CPL 60.42 violated defendants’ constitutional rights to confront witnesses and present a defense.
2. Whether the trial court erred by refusing to give a specific jury instruction that an honest (and reasonable) mistaken belief in consent required acquittal.

## Decision

- The Court of Appeals of New York affirmed the convictions.
- The court held the CPL 60.42 exclusion was a permissible evidentiary limitation and did not violate confrontation or due process rights.
- The court held no separate mistake-of-fact-as-to-consent instruction was required because the forcible compulsion and nonconsent instructions adequately framed the elements the prosecution had to prove beyond a reasonable doubt.

## Legal Principles

- A defendant’s rights to confront witnesses and present a defense are fundamental but may be limited by evidentiary rules that are not arbitrary or disproportionate to their legitimate purposes.
- New York’s rape-shield statute (CPL 60.42) generally bars evidence of a complainant’s prior sexual conduct, subject to limited exceptions; courts may exclude marginally probative and highly prejudicial sexual-history evidence after an in camera review.
- First-degree rape and first-degree sodomy based on “forcible compulsion” require proof of intentional sexual acts accomplished by force or threat and resulting lack of consent; no additional mens rea directed specifically to nonconsent must be separately charged.
- When the jury charge, read as a whole, correctly states the law and requires the prosecution to prove forcible compulsion and lack of consent beyond a reasonable doubt, a separate instruction on mistaken belief in consent is not required.

## Conclusion

The court sustained the use of New York’s rape-shield law to exclude speculative, prejudicial sexual-history evidence and held that instructions requiring proof of forcible compulsion and nonconsent sufficiently addressed the defense theory, making a distinct mistake-of-consent charge unnecessary.


People v. Williams, 81 N.Y.2d 303, 614 N.E.2d 730 (N.Y. 1993)