Page 27 of 42 103 Minn. L. Rev. 844, *896 sexual assault reports are ineffective. Police clearance-by-arrest rates are low. !74 Detailed studies of how police departments handle reported sexual assault cases find "substantial attrition," [*897] typically at the point when police decide whether to make an arrest. !7° In the Los Angeles Police Department, only one report in nine was cleared by arrest; one in ten resulted in prosecution. !7° One hurdle lies in forensic evidence development: law enforcement agencies nationwide have suffered long backlogs in testing rape evidence kits, !77 although federal funding has recently helped reduce that problem. !76 Notoriously, things used to be much worse. Under the common law definition, rape convictions required proof that the offender used force to overcome the victim's "utmost resistance." !7? Evidence of women's - and only women's - prior sexual conduct or reputation for "unchastity" was a permissible basis on which to infer consent. '8° The law excluded rape of one's spouse from [#898] the offense definition. '8! Prosecutors and police were openly skeptical of rape accusations and reluctant to investigate. 18? Yet much of this legal infrastructure intended to restrict rape law enforcement has been abolished. Rape offenses have been revised to eliminate resistance requirements, and many states also removed the requirement to prove use of force. !83 Evidence rules are now more favorable to sexual assault complammants: rape shield laws in all jurisdictions prohibit use of a complainant's past sexual behavior as character evidence or a basis on which to infer consent, !** while evidence rules in federal courts and nineteen states permit evidence of the defendant's past sexual offenses to show propensity to commit sexual assaults. !85 Some police departments have officers specially trained in sexual assault investigations, and prosecutors’ offices (as required by statute in some states) have specially trained units dedicate