## Facts

- The complainant went with Chris Manning to Jeffrey D. Long’s apartment, where the three drank alcohol.
- The State’s evidence was that Long and Manning beat and sexually assaulted the complainant and forced her into the hallway outside the apartment.
- The complainant remained in the hallway until morning, later went home, bathed, and reported the incident to police a few days later.
- A medical exam showed bruising, rectal trauma, and vaginal tears and abrasions consistent with sexual assault.
- A search of Long’s apartment produced no physical evidence that an assault occurred there, and there was no physical evidence directly linking Long to the charged crimes.
- Long denied assaulting the complainant; there were no eyewitnesses other than the complainant and the alleged assailants.
- To impeach the complainant’s credibility, Long offered proof that she had previously made false allegations against another man, including claims of being struck with a rock, threatened, and sexually assaulted; the proffers included recantations.
- The trial court excluded the proffered testimony as inadmissible extrinsic evidence of the complainant’s character for truthfulness.
- Long was convicted of forcible rape and forcible sodomy and appealed, arguing the exclusion violated evidentiary rules and his constitutional rights.

## Issues

1. Whether a defendant may introduce evidence that a complainant previously made demonstrably false allegations of physical or sexual assault to impeach credibility in a sexual-offense prosecution.
2. Whether the trial court abused its discretion by excluding such impeachment evidence as improper extrinsic character evidence.
3. Whether categorical exclusion of this evidence violated the defendant’s rights to confront witnesses and to present a defense where the case largely turned on the complainant’s credibility.

## Decision

- The Supreme Court of Missouri (en banc) reversed Long’s convictions and remanded.
- The court held the trial court abused its discretion by prohibiting Long from introducing evidence of the complainant’s prior false allegations.
- The court concluded the exclusion deprived Long of significant impeachment evidence in a case dependent on the complainant’s credibility.
- The court determined the error was prejudicial and required a new trial.

## Legal Principles

- Evidence that a complaining witness previously made demonstrably false allegations of physical or sexual assault may be admissible to impeach credibility, subject to relevance and balancing limits.
- Such proof is not automatically barred as extrinsic evidence offered solely to show a witness’s general character for untruthfulness; it may constitute focused impeachment bearing directly on the truth of the present accusation.
- Trial courts have discretion to limit impeachment evidence, but discretion is exceeded when exclusion materially prevents meaningful testing of a central witness’s credibility.
- Excluding critical impeachment evidence in a credibility-driven prosecution can violate the Confrontation Clause and due process protections associated with the right to present a defense.

## Conclusion

The court reversed and remanded because the trial court’s categorical exclusion of evidence that the complainant had previously made and recanted false assault accusations improperly prevented significant credibility impeachment, undermining Long’s confrontation and defense rights in a case largely decided by the complainant’s testimony.


State v. Long, 140 S.W.3d 27 (Mo. 2004) (en banc)