Rayner v. State, 307 Ga. App. 861

Rayner was convicted after a jury trial of child molestation, criminal attempt to commit rape, and false imprisonment; he received ten years to serve and ten years on probation.
On appeal, Rayner challenges the trial court’s jury instructions on prior difficulties, the court’s handling of expert testimony, the cross-examination limits, and the exclusion of prior false-allegation evidence and related cross-examination of witness Charlene.
C. E., then fourteen, testified she began alleging abuse by Rayner, her uncle, when she was nine, describing multiple encounters at Rayner’s home.
Charlene Fruitt, C. E.’s mother, described the family dynamics, C. E.’s disclosure, and the delay and method of reporting the alleged abuse to authorities.
Detective Moore corroborated the reporting timeline; Rayner denied ever touching C. E. but acknowledged times alone with her.
The appellate court affirmed, addressing each challenge and finding no reversible error in the trial proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did jury instruction on prior difficulties convey the court’s opinion?	Rayner argues the instruction telegraphed support for the State’s theory.	Rayner contends there was no admissible prior-difficulties evidence suitable for that charge.	No error; instruction supported by admissible prior-difficulties evidence.
Was the expert’s testimony improperly restricted?	Rayner asserts the expert’s critique of interviewing methods was unfairly curtailed.	Rayner’s expert testimony on interviewing techniques and believability was appropriately limited.	No reversible error; trial court did not improperly bar admissible testimony.
Was evidence of prior false allegations improperly admitted or cross-exam restricted?	Rayner sought to admit prior false-allegation evidence and cross-examine about it.	The court properly held a threshold determination and excluded that evidence when credibility findings favored the victim.	No error; threshold determination supported exclusion.
Did the trial court improperly limit cross-examination of Charlene’s statements via the grandmother?	Rayner contends cross-examination was necessary to challenge credibility.	Grandmother’s statements were hearsay and cross-examination subject to trial discretion.	No reversible error; even if restricted, no harm shown given other credibility evidence.

Goldstein v. State, 273 Ga. 1 (Ga. Supreme Court 1989) (not controlling where pre-trial admissibility determined)
Stillwell v. State, 294 Ga. App. 805 (Ga. App. 2008) (evidence of prior sexual conduct admissible where appropriate)
Newsome v. State, 289 Ga. App. 590 (Ga. App. 2008) (pattern jury charge approved for similar issue)
Hammontree v. State, 283 Ga. App. 736 (Ga. App. 2007) (prior-difficulties evidence admissible; no notice required)
Barlow v. State, 270 Ga. 54 (Ga. 1998) (prior act admissibility to show motive and bent of mind)
Roberson v. State, 214 Ga. App. 208 (Ga. App. 1994) (cross-examination and credibility considerations in sexual offenses)
Carpenter v. State, 167 Ga. App. 634 (Ga. App. 1983) (credibility and sufficiency of victim’s testimony)
Wells v. State, 281 Ga. 253 (Ga. 2006) (credible testimony can sustain conviction without physical corroboration)