Supreme Court of Georgia

Atkins v. the State.

August 20, 2018818 S.E.2d 567

Summary

The court held that a statutory-rape victim's prior consistent statements cannot, standing alone, satisfy the statutory corroboration requirement because corroborating evidence must be independent of the victim's testimony. Because the State presented no other sufficient evidence connecting Atkins to the alleged statutory rape, that conviction was reversed, while the aggravated-child-molestation conviction was affirmed. The court also upheld the exclusion of broad questioning into the victim's sexual history because Atkins sought a nonspecific fishing expedition rather than particular evidence bearing on a motive to fabricate.