Hall v. State, 320 Ga. App. 48

Hall offered two girls under sixteen money for sex; he engaged in intercourse and oral sex with one girl in the presence of the other.
The state presented no medical or expert medical testimony at trial.
Hall argued the state opened the door to evidence of the victim's prior sexual involvement with another man.
The trial court ruled the prior-acts evidence irrelevant and inadmissible to prove the victim's character or sexual propensity.
The court discussed medical testimony and child abuse accommodation syndrome as potential bases for admitting otherwise inadmissible evidence.
This court affirmed Hall’s convictions, holding the exclusion of the challenged prior-sexual-history evidence was not an abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of prior sexual history	Hall contends the state’s elicited testimony opened the door to prior sexual history.	State contends such evidence is irrelevant absent medical testimony and not admissible to show nonchastity or preoccupation with sex.	Exclusion proper; not relevant without medical testimony
Door-opening by victim testimony	Hall argues statements about embarrassment and counseling imply prior abuse by another man.	State maintains no medical testimony or abuse syndrome linkage was established.	No error; testimony did not establish medical grounds for admissibility
Medical testimony standard	Hall claims the testimony amounted to medical testimony requiring other-acts evidence.	State did not present medical testimony and the court properly excluded related evidence.	No medical testimony requirement; exclusion was proper
Citing child abuse accommodation syndrome	Hall relies on accommodation-syndrome reasoning to admit alternative causes.	No syndrome evidence was presented here to connect symptoms to abuse by someone else.	Distinguishable; no basis to admit other-acts evidence

Hall v. State, 282 Ga. 294 (2007) (relevance and medical testimony considerations in child molestation cases)
Keri v. State, 179 Ga. App. 664 (1986) (child sexual abuse accommodation syndrome categories)
Blackwell v. State, 196 Ga. App. 523 (1990s) (distinguishes when prior sexual acts are admissible absent medical evidence)
Segura v. State, 280 Ga. App. 685 (2006) (factors for admitting evidence related to abuse findings)
Holmes v. State, 275 Ga. 853 (2002) (psychiatric considerations in admissibility)
Burris v. State, 204 Ga. App. 806 (1992) (prior acts and admissibility considerations in abuse cases)