## Facts

- A criminal prosecution involved allegations of sexual misconduct against the defendant.
- The defense sought to introduce evidence relating to the complainant’s prior accusations of sexual conduct.
- The prosecution invoked Ohio’s rape-shield statute to exclude the proffered evidence.
- The trial court ruled on admissibility under the rape-shield statute and general evidentiary principles.
- The case reached the Ohio Supreme Court on review of the scope and application of the rape-shield rule.

## Issues

1. Whether Ohio’s rape-shield statute bars evidence that a complainant previously made false accusations of sexual misconduct.
2. What foundational showing is required before a defendant may introduce evidence of alleged prior false accusations.
3. How courts should balance rape-shield protections against a defendant’s right to present a defense and impeach credibility.

## Decision

- The Ohio Supreme Court held that the rape-shield statute does not categorically bar evidence that the complainant previously made false accusations.
- The Court required a threshold evidentiary showing that the prior accusation was false before such evidence may be admitted.
- The Court emphasized trial-court gatekeeping through relevance, probative-value, and unfair-prejudice analysis.
- The Court directed that admissibility turns on the specific proffer and the evidentiary foundation rather than a general attack on the complainant’s character.

## Legal Principles

- Rape-shield statutes generally exclude evidence offered to prove a complainant’s sexual activity or sexual predisposition, subject to recognized exceptions and constitutional limits.
- Evidence of a complainant’s alleged prior false accusations is treated as credibility impeachment, but admission requires a concrete foundation of falsity, not speculation.
- Trial courts must evaluate such proffers for relevance and must exclude evidence whose probative value is substantially outweighed by unfair prejudice, confusion, or harassment.
- A defendant’s right to confrontation and to present a defense may require admission of otherwise excluded evidence when the showing is specific and material to credibility.

## Conclusion

The Ohio Supreme Court concluded that rape-shield protections do not automatically foreclose evidence of prior false accusations, but admission is permitted only when the defense establishes an adequate foundation of falsity and the trial court finds the evidence sufficiently probative under standard evidentiary balancing.


State v. Smith, 80 Ohio St. 3d 89, 684 N.E.2d 668 (Ohio 1997)