Indiana Code

Ind. Code § 35-37-4-4 (2026)

Sex crimes; admissibility of evidence of past sexual conduct; procedure

✓ current as of May 2026
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     Sec. 4. (a) In a prosecution for an offense described in IC 11-8-8-4.5(a):

(1) evidence of the victim's past sexual conduct;

(2) evidence of the past sexual conduct of a witness other than the accused;

(3) opinion evidence of the victim's past sexual conduct;

(4) opinion evidence of the past sexual conduct of a witness other than the accused;

(5) reputation evidence of the victim's past sexual conduct; and

(6) reputation evidence of the past sexual conduct of a witness other than the accused;

may not be admitted, nor may reference be made to this evidence in the presence of the jury, except as provided in this chapter.

     (b) Notwithstanding subsection (a), evidence:

(1) of the victim's or a witness's past sexual conduct with the defendant;

(2) which in a specific instance of sexual activity shows that some person other than the defendant committed the act upon which the prosecution is founded; or

(3) that the victim's pregnancy at the time of trial was not caused by the defendant;

may be introduced if the judge finds, under the procedure provided in subsection (c), that it is material to a fact at issue in the case and that its inflammatory or prejudicial nature does not outweigh its probative value.

     (c) If the defendant or the state proposes to offer evidence described in subsection (b), the following procedure must be followed:

(1) The defendant or the state shall file a written motion not less than ten (10) days before trial stating that it has an offer of proof concerning evidence described in subsection (b) and its relevancy to the case. This motion shall be accompanied by an affidavit in which the offer of proof is stated.

(2) If the court finds that the offer of proof is sufficient, the court shall order a hearing out of the presence of the jury, and at the hearing allow the questioning of the victim or witness regarding the offer of proof made by the defendant or the state.

At the conclusion of the hearing, if the court finds that evidence proposed to be offered by the defendant or the state regarding the sexual conduct of the victim or witness is admissible under subsection (b), the court shall make an order stating what evidence may be introduced by the defendant or the state and the nature of the questions to be permitted. The defendant or the state may then offer evidence under the order of the court.

     (d) If new information is discovered within ten (10) days before trial or during the course of the trial that might make evidence described in subsection (b) admissible, the judge shall order a hearing out of the presence of the jury to determine whether the proposed evidence is admissible under this chapter.

     (e) This section does not limit the right of either the state or the accused to impeach credibility by a showing of prior felony convictions.

     (f) If:

(1) a defendant files a motion under subsection (c)(1) concerning evidence described in subsection (b)(3); and

(2) the state acknowledges that the victim's pregnancy is not due to the conduct of the defendant;

the court shall instruct the jury that the victim's pregnancy is not due to the conduct of the defendant. However, other evidence concerning the pregnancy may not be admitted, and further reference to the pregnancy may not be made in the presence of the jury.

As added by Acts 1981, P.L.298, SEC.6. Amended by P.L.322-1983, SEC.1; P.L.144-2018, SEC.17.

 

Notes of Decisions
Cited in 71 cases (5 in the last 5 years), 1984–2026 · leading case: Hodges v. State, 524 N.E.2d 774 (Ind. 1988).
Hodges v. State, 524 N.E.2d 774 (Ind. 1988). · cites it 19× “as the procedures set forth in Ind. Code § 35-37-4-4 were not followed and the evidence was without proper foundation, was not relevant, and was highly prejudicial.”
Sallee v. State, 785 N.E.2d 645 (Ind. Ct. App. 2003). · cites it 16× “) (citing Ind. Code § 35-37-4-4 ). To the extent there is a difference between the two, the rule controls.”
Oatts v. State, 899 N.E.2d 714 (Ind. Ct. App. 2009). · cites it 6× “Evidence Rule 412, the Rape Shield Rule, “incorporates the basic principles” of Ind.Code § 35-37-4-4, 7 Indiana’s Rape Shield Act.”
Stewart v. State, 531 N.E.2d 1146 (Ind. 1988). · cites it 8× “Ind. Code § 35-37-4-4 . The rule in Little stated that the falsity of the victim's accusations must be admitted by him or her or the allegations must be demonstrably false before the victim may be impeached.”
Sallee v. State, 777 N.E.2d 1204 (Ind. Ct. App. 2002). · cites it 6× “The Rape Shield Statute, Ind.Code § 35-37-4-4, predates Evidence Rule 412.”
Caley v. State, 650 N.E.2d 54 (Ind. Ct. App. 1995). · cites it 18× “'s credibility through cross-examination. Evidence of the sexual history of an alleged victim of a sexual offense is generally inadmissible in the trial of the alleged offender.”
Williams v. State, 681 N.E.2d 195 (Ind. 1997). · cites it 6× “Rule 412 is intended to prevent the victim from being put on trial, to protect the victim against surprise, harassment, and unnecessary invasion of privacy, and, importantly, to remove obstacles to reporting sex crimes.”
Lonnie K. Stephens v. Charles B. Miller, Warden, & Attorney Gen. of the State of Indiana, 13 F.3d 998 (7th Cir. 1994). · cites it 4× “It protects victims from needless exposure of their past sexual conduct; ensures that the focus of rape trials remains the guilt or innocence of the accused rather than the sexual history of the complainant; and, by reducing the embarrassment and anguish of trial, encourages…”
Clark v. State, 728 N.E.2d 880 (Ind. Ct. App. 2000). · cites it 6× “Evidence Rule 412; Ind.Code § 35-37-4-4. 2 Furthermore, the trial court gave a preliminary instruction on child molesting as follows: A person who, with a child under fourteen (14) years of age, performs or submits to deviate sexual conduct commits child molesting.”
State v. Walton, 715 N.E.2d 824 (Ind. 1999). · cites it 5× “Discussion Indiana’s Rape Shield Act, originally promulgated as Indiana Code § 35-37-4-4, generally prohibited the admission of evidence relating to a rape victim’s sexual history.”
Henry Tague v. Thomas Richards & Attorney Gen. of the State of Indiana, 3 F.3d 1133 (7th Cir. 1993). · cites it 3× “On appeal, Tague raises several issues, most important of which are whether the state trial court’s application of Indiana’s rape shield statute, Ind.Code § 35-37-4-4, violated his Sixth Amendment right to confrontation, and whether allowing amendment of the charging information…”
Zawacki v. State, 753 N.E.2d 100 (Ind. Ct. App. 2001). · cites it 4× “I.C. § 35-37-4-4; Evid.R. 412. The purpose of the Rape Shield Law is to encourage the reporting of sexual assaults and to prevent victims from feeling as though they are on trial for their sexual histories.”
Ind. Code § 35-37-4-4(a): 4 cases
Sallee v. State, 777 N.E.2d 1204 (Ind. Ct. App. 2002). “The Rape Shield Statute, Ind.Code § 35-37-4-4, predates Evidence Rule 412.”
Barnes v. Barnes, 603 N.E.2d 1337 (Ind. 1992).
Lonnie K. Stephens v. Charles B. Miller, Warden, & Attorney Gen. of the State of Indiana, 13 F.3d 998 (7th Cir. 1994). “It protects victims from needless exposure of their past sexual conduct; ensures that the focus of rape trials remains the guilt or innocence of the accused rather than the sexual history of the complainant; and, by reducing the embarrassment and anguish of trial, encourages…”
Henry Tague v. Thomas Richards & Attorney Gen. of the State of Indiana, 3 F.3d 1133 (7th Cir. 1993). “On appeal, Tague raises several issues, most important of which are whether the state trial court’s application of Indiana’s rape shield statute, Ind.Code § 35-37-4-4, violated his Sixth Amendment right to confrontation, and whether allowing amendment of the charging information…”
Ind. Code § 35-37-4-4(b): 4 cases
Sallee v. State, 785 N.E.2d 645 (Ind. Ct. App. 2003). “) (citing Ind. Code § 35-37-4-4 ). To the extent there is a difference between the two, the rule controls.”
Caley v. State, 650 N.E.2d 54 (Ind. Ct. App. 1995). “'s credibility through cross-examination. Evidence of the sexual history of an alleged victim of a sexual offense is generally inadmissible in the trial of the alleged offender.”
Henry Tague v. Thomas Richards & Attorney Gen. of the State of Indiana, 3 F.3d 1133 (7th Cir. 1993). “On appeal, Tague raises several issues, most important of which are whether the state trial court’s application of Indiana’s rape shield statute, Ind.Code § 35-37-4-4, violated his Sixth Amendment right to confrontation, and whether allowing amendment of the charging information…”
Ind. Code § 35-37-4-4(b)(2): 4 cases
Caley v. State, 650 N.E.2d 54 (Ind. Ct. App. 1995). “'s credibility through cross-examination. Evidence of the sexual history of an alleged victim of a sexual offense is generally inadmissible in the trial of the alleged offender.”
Thomas v. State, 471 N.E.2d 677 (Ind. 1984).
DeMotte v. State, 555 N.E.2d 1336 (Ind. Ct. App. 1990).
Ditchley v. State, 542 N.E.2d 996 (Ind. 1989).
Ind. Code § 35-37-4-4(c): 3 cases
Sallee v. State, 785 N.E.2d 645 (Ind. Ct. App. 2003). “) (citing Ind. Code § 35-37-4-4 ). To the extent there is a difference between the two, the rule controls.”
Sallee v. State, 777 N.E.2d 1204 (Ind. Ct. App. 2002). “The Rape Shield Statute, Ind.Code § 35-37-4-4, predates Evidence Rule 412.”
Stephens v. State, 544 N.E.2d 137 (Ind. 1989).
Ind. Code § 35-37-4-4(c)(l): 1 case
Mason v. Indiana, 511 N.E.2d 487 (Ind. Ct. App. 1987).
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