State v. Hall, 2014 Ohio 2094

Hall was convicted of rape of Sara, who was 11 at the time of the alleged offense.
Sara testified about the 2007 rape; Hall was in a relationship with Sara’s mother at the time.
Sara reported the abuse four years later; Sara’s mother initially doubted the claim and they later moved briefly then returned.
Dr. Lori Vavul-Roediger, an expert pediatrician, testified based on Sara’s disclosures and medical findings, including a healed hymenal tear.
Hall attempted to cross-examine Sara about prior false accusations; the trial court did not hold an in camera Boggs hearing, and the cross-examination was blocked.
The court remanded for an in camera Boggs hearing to determine whether prior accusations involved sexual activity or were unfounded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether cross-exam on prior false accusations was properly allowed	Hall contends prior false-accusation evidence is admissible under Boggs for impeachment.	State argues such cross-examination risks sexual-activity disclosures and should be limited by rape-shield rules.	First assignment sustained; remand for in camera Boggs hearing.
Whether trial counsel was ineffective for failing to impeach with prior false accusations	Defense failed to present aunt/Jane witnesses to impeach credibility.	Counsel’s strategy and other trial errors negate a finding of ineffectiveness.	Second assignment overruled; remand for Boggs hearing may cure the issue.
Whether prosecutorial misconduct occurred	Prosecutor’s remarks were improper and prejudicial.	Any remarks were not prejudicial given the instructions and context.	Third assignment overruled; no plain error found.
Whether the verdict is against the manifest weight of the evidence	Doctor's testimony and lack of physical evidence undermine credibility.	Credibility determinations and witness testimony support conviction.	Fourth assignment overruled; conviction affirmed pending remand for Boggs hearing.

State v. Boggs, 63 Ohio St.3d 418 (1992) (cross-examination on prior false rape accusations requires in camera hearing to separate sexual activity from unfounded claims)
State v. Chaney, 169 Ohio App.3d 246 (2006) (cross-examination on prior false accusations for impeachment when not involving sexual activity)
State v. Netherland, 132 Ohio App.3d 252 (1999) (trial court discretion to admit or exclude prior-accusation evidence under Evid.R. 608(B))
State v. Ferguson, 5 Ohio St.3d 160 (1983) (distinguishes references to uncontradicted evidence in closing argument from comments on failure to testify)