ABSTRACT
Although the rapes that prostitutes suffer are especially frequent and violent, prostitutes rarely report having been attacked to police and, when they do, those reports rarely end in convictions of their attackers. One reason for this low conviction rate is the admission of evidence of the complainant's prior prostitution at trial to prove that she consented to the sexual intercourse alleged to have been rape. Some courts hold that such evidence is admissible when the defendant claims that what happened on the instance in question was an act of prostitution. Other courts hold that it is inadmissible unless it proves the complainant's bias or a motive to fabricate a claim of rape. Still other courts hold that it is inadmissible unless it reveals prior threats to retaliate against a customer.