State v. Rolon
In State v. Rolon, 257 Conn. 156, 173, 777 A.2d 604 (2001), the victim was sexually abused beginning when she was eight months old until she was five years old. Id., 161-62. The defendant in Rolon sought to introduce evidence that the victim was sexually abused by someone other than the defendant to show an alternative source of the young victim's sexual knowledge. Id., 172-73.
In allowing the evidence of the victim's prior sexual conduct, Rolon distinguished State v. Kulmac, 230 Conn. 43, 644 A.2d 887 (1994), which affirmed a trial court's exclusion of such evidence of prior sexual abuse.
The court in Rolon noted that "the victims in Kulmac were ages fourteen and fifteen at the time of trial . . . an age at which most young adults are less likely to be confused over an individual's identity and are capable of understanding matters of a sexual nature. . . . The victims were old enough to understand and clearly articulate the identity of their abuser." State v. Rolon, supra, 257 Conn. 180-81.