State v. Johnson
Supreme Court of New Mexico
944 P.2d 869 (1997)
The State of New Mexico (plaintiff) prosecuted Richard Leonard Johnson (defendant) for raping two women. At trial, Johnson tried to introduce evidence that the women had worked as prostitutes, arguing its probative value outweighed the risk of prejudice, but he never explained how the evidence was actually relevant. The trial judge excluded it and the jury convicted him. The appellate court reversed, guessing from parts of the record that Johnson meant to use the evidence to suggest the women had a motive to fabricate the charges. The state appealed to the New Mexico Supreme Court.
Whether rape-shield laws generally exclude evidence of a complainant's sexual history except when its probative value outweighs its prejudicial effect.