lice (72). Silbert also noted that "the rapes in study especially those occurring after the subjects entered prostitution, involved more rapists who were strangers, more use of force, and more serious injury to the victim than rapes of women who were not prostitutes" (72).Having excluded rapes by customers, Silbert concluded that the extraordinarily high rape rate revealed in this study was not directly due to the womens' work as prostitutes. He stated, "Instead, the rapes were associated with the victims' vulnerability as women living in high-crime areas of the city and working during high-crime hours" (73). Given these findings it makes no sense to treat prostitutes' rape complaints as less credible than those of other women.The New Mexico Supreme Court barred evidence of a motive to lie in one such case in 1997. Defendant Richard Leonard Johnson claimed that on different nights he had picked up two prostitutes who accused him of rape after he refused to pay them. The trial judge barred any evidence of the women's sexual pasts. The decision was based on a detective's testimony that one woman told him she was not working as a prostitute the night she met Johnson, and that the other prostituted herself only occasionally to pay her rent. The appeals court reversed, holding Johnson's evidence "went to the issue of whether the victims had reason to fabricate the rape to avenge defendant's failure or refusal to pay them" (Gibeaut 32). The state supreme court reversed again, saying Johnson had to show something more, such as a pattern of extortion attempts. He stated, "Simply showing that the victim engaged in an act or acts of prostitution is not sufficient to show a motive to fabricate" (32).Evidence that the defendant and the complainant previously were lovers is extremely effective in persuading police not to investigate a rape complaint and jurors not to believe it. Judges also have been known to take a low view of such cases ...
