Gallegos-Munoz v. State

Summary

The court held that the former probable-falsity threshold for admitting evidence that a sexual-assault complainant previously made a false accusation does not apply to prosecutions governed by Georgia's 2013 Evidence Code. Such evidence must instead be evaluated under the Code's generally applicable rules, including relevance, character-evidence restrictions, and Rule 403 balancing, with no categorical rule requiring proof of probable falsity first. Because the lower courts applied the displaced threshold and did not conduct the required analysis, the court vacated the judgment and remanded for reconsideration.