White v. State
Maryland Court of Appeals
598 A.2d 187 (1991)

- Written by Sean Carroll, JD
Facts
Richard and Adrian White (defendants) were charged with raping a woman. At trial, the Whites testified that the victim had asked them to find cocaine for her but they could not find enough. They also testified that while making those requests, the victim made suggestive sexual moves toward them. The Whites sought to introduce witness testimony that the victim had offered sex for drugs on a different occasion. The trial court excluded the testimony based on Maryland’s rape-shield statute. The Maryland Court of Special Appeals affirmed. The Maryland Court of Appeals granted the Whites’ petition for certiorari. The Whites argued that their proffered testimony was admissible to prove that the victim had an ulterior motive in accusing them of rape. Specifically, the Whites claimed that (1) the victim was angry at them for not finding enough cocaine and (2) the accusation protected the victim from her fiancé finding out that she was out with other men doing cocaine.
Rule of Law
Issue
Holding and Reasoning (Chasanow, J.)
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