The following excerpt is from United States v. Rivera, 799 F.3d 180 (2nd Cir. 2015):
Everything turned on the government's ability to convince the jury that the victims were deceived, and a reasonable jury might have received a significantly different impression of the witness' credibility if defendants had been permitted to establish that the victims previously worked in sexualized environments. Olden, 488 U.S. at 23132, 109 S.Ct. 480 (internal alterations and quotation marks omitted); cf. United States v. Shellef, 507 F.3d 82, 107 (2d Cir.2007) (Where a jury is presented with multiple theories of conviction, one of which was invalid, the jury's verdict must be overturned if it is impossible to tell which theory formed the basis for conviction. (internal quotation marks omitted)). As defendants argued here and before the district court, see VA 147, evidence of prior work in a sexualized environment goes to the heart of their defense. See United States v. Forrester, 60 F.3d 52, 6465 (2d Cir.1995) (Error going to the heart of a critical issue is less likely to be harmless. (internal quotation marks omitted)).
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