State v. Jeffries (Slip Opinion), 156 N.E.3d 859

Victim D.S. lived with appellant Cedric Jeffries from age 6 until 2016; she later reported repeated sexual abuse by Jeffries over about nine years.
Jeffries was indicted on kidnapping and rape charges for two specific incidents when D.S. was 12 and 16; he was tried, convicted, and sentenced to an aggregate 15 years to life.
During discovery, defense learned D.S. had reported being sexually assaulted by a foster brother at age four or five and sought to introduce that prior allegation at trial.
The trial court held an in camera (Boggs) hearing, found the foster-brother allegation credible, but ruled Ohio’s rape-shield statute barred admission of the prior sexual-assault evidence.
On appeal Jeffries argued the rape-shield law applies only to consensual sexual conduct and that excluding the prior assault evidence violated his confrontation and due-process rights.
The Ohio Supreme Court held the statutory term “sexual activity” unambiguously includes both consensual and nonconsensual sexual activity, affirmed the exclusion, and declined to resolve the as-applied constitutional claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Ohio’s rape‑shield prohibition on evidence of a victim’s "specific instances of sexual activity" covers prior nonconsensual sexual activity	State: "sexual activity" (per R.C. 2907.01) encompasses sexual conduct/contact regardless of consent; statute unambiguous	Jeffries: statute meant to bar only consensual sexual history; prior sexual assaults are admissible	Court: held the statutory definition includes both consensual and nonconsensual activity; such evidence is barred unless a statutory exception applies
Whether exclusion of prior nonconsensual‑activity evidence violated defendant’s confrontation/due‑process rights	State: constitutional issue not decided by this appeal	Jeffries: exclusion deprived him of relevant, constitutionally required evidence	Court: did not accept jurisdiction over this constitutional claim and expressly left it for another day

State v. Boggs, 63 Ohio St.3d 418 (Ohio 1992) (prior true accusations of sexual assault constitute "sexual activity" and warrant Boggs in camera review)
State v. Williams, 134 Ohio St.3d 521 (Ohio 2012) (addressing admissibility of defendant’s other sexual‑act evidence under Evid.R. 404(B) and R.C. 2945.59; did not decide rape‑shield issue)
State v. Schaim, 65 Ohio St.3d 51 (Ohio 1992) (recognizes rape‑shield law’s role when assessing admissibility of other‑acts sexual‑abuse evidence)
State v. Gardner, 59 Ohio St.2d 14 (Ohio 1979) (summarizes rape‑shield law purposes: prevent harassment, avoid trying the victim, encourage reporting, exclude inflammatory low‑probative evidence)
State v. Meadows, 28 Ohio St.3d 43 (Ohio 1986) (uses statutory "sexual activity" concept in context of child pornography/pandering prohibitions)