The State of Washington, Petitioner v. Allen Dale Hudlow, Respondent; the State of Washington, Petitioner, v…

Summary

The court reversed the Court of Appeals and reinstated Hudlow's and Harper's convictions, holding that the proffered evidence of the victims' prior sexual conduct was minimally relevant at most and was properly excluded under the rape-shield statute. It also held that the prosecution had not opened the door to cross-examination about the victims' prior sexual behavior and that the trial court did not abuse its discretion in limiting that cross-examination. The court separately remanded Hudlow's preserved challenge to his habitual-criminal status to the Court of Appeals. Utter, J., dissenting, would have held that the prosecution opened the door and that the defendants were entitled to further cross-examination about prior sexual conduct.