Supreme Court of Georgia
State v. Burns.
June 10, 2019829 S.E.2d 367
Summary
The court held that evidence of a complainant's prior false accusation is not categorically admissible based on confrontation or due-process principles, overruling the prior constitutional rule requiring admission. The prior evidentiary interpretation of the rape-shield statute remains valid, but the evidence remains subject to the ordinary balancing required by OCGA § 24-4-403. Applying that standard, the court concluded that the trial court abused its discretion in excluding the evidence and affirmed the intermediate appellate court's reversal.