How have courts dealt with the issue of false imprisonment and sexual assault cases?

For example, in People v. Mendoza (1987) 192 Cal.App.3d 667, 238 Cal.Rptr. 1 the Court of Appeal affirmed the trial court's judgment convicting defendant of false imprisonment and attempted rape. The issue on appeal was whether a defendant's exculpatory statements to police officers may be used to show his consciousness of guilt and therefore his guilt. There, in an attempt to account for his whereabouts, the defendant told police he had just finished washing his friend's pickup truck. Yet, one of the officers had noticed a light layer of dust all over the truck. Thus, the statement, although exculpatory, was false.

The court held the defendant's statement was contradicted and hence proven false by the officers' statements. The court explained, "[f]alse statements which 'are apparently motivated by fear of detection, .. suggest there is no honest explanation for the incriminating circumstances' and may be used as evidence of the accused's guilt." (Id. at p. 673, 238 Cal.Rptr. 1 citing People v. Albertson (1944) 23 Cal.2d 550, 582, 145 P.2d 7 [Traynor, J., conc.].)