Gallegos-Munoz v. State

Summary

The court held that the former requirement of proving a reasonable probability that a victim's prior accusation against another person was false no longer applies under Georgia's 2013 Evidence Code. Such evidence is instead governed by the Code's generally applicable rules, including relevance, character-evidence restrictions, and, when appropriate, Rule 403 balancing. Because the lower courts applied the displaced threshold test and did not conduct the required analysis, the court vacated and remanded for reconsideration of the motion for a new trial.