White v. the State.

Summary

The court held that Georgia's Rape Shield Statute applies equally to evidence offered by the State and permits admission of a complaining witness's past sexual behavior only under the statute's specific consent-related exception. The trial court therefore erred by admitting evidence of S.M.'s prior sexual misconduct, but the error did not satisfy plain error review because it did not likely affect the trial's outcome. Bethel, J., concurring, agreed with affirmance but would rely on the fourth plain-error prong rather than the majority's conclusion that the error did not likely affect the outcome.