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Criminal Law: Rape-Exclusion of Prior Victim Allegations

Staff Report//July 9, 2026//

Criminal Law: Rape-Exclusion of Prior Victim Allegations

Staff Report//July 9, 2026//

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Defendant appealed his convictions for second-degree rape, arguing that the trial court erred in excluding evidence of the victim’s prior rape allegation.

Where defendant failed to prove by a preponderance of the evidence that the victim’s prior allegation was false, it was inadmissible to challenge her credibility to show that she had a motive to fabricate her allegations against defendant. Furthermore, the lack of connection between the allegations meant there was no exception to the rape shield law.

Judgment is affirmed.

State v. Wooten (MLW No. 84943/Case No. ED113976 – 19 pages) (Missouri Court of Appeals, Eastern District, Gaertner, J.) Appealed from circuit court, St. Louis County, Ribaudo, J. (Matthew G. Mueller for appellant) (Catherine L. Hanaway and Riley A. O’Shaughnessy for respondent)

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