Page 37 of 42 103 Minn. L. Rev. 844, *913 Comm. on the Judiciary) (noting that there are over 542,000 untested rape kits); Caitlin Dickson, How the U.S. Ended Up With 400,000 Untested Rape Kits, Daily Beast (Sept. 23, 2014), https:/Awww_ .thedailybeast.com/how-the-us-ended-up-with-400000-untested-rape-kits; Dayton — Uttinger, Why Is There Still a Rape’ Kit Backlog?, Women's Media Ctr. (Aug. 1, 2017), http://www.womensmediacenter.com/fbomb/why-is-there-still-a-rape-kit-backlog ("There are an estimated 175,000 untested rape kits ... across the US ... ."). 178 See Office on Violence Against Women, U.S. Dep't of Justice, Sexual Assault Kit Testing Initiatives and Non-Investigative Kits 3 (2017), hitps://www.justice.gov/ovw/page/file/931391/download (noting that $ 100 million was awarded to states and localities in 2014-16 to reduce rape kit backlog). 179 Note, Recent Statutory Developments in the Definition of Forcible Rape, 61 Va. L. Rev. 1500, 1505-07 (1975). 180 See, e.g., State v. Sibley, 33 S.W. 167, 171 (Mo. 1895) ("The rule in this state permitting a witness to be impeached by proof of general reputation for unchastity is confined to females."); People v. Abbot, 19 Wend. 192, 194 (N.Y. 1838) (permitting questions to the rape complainant about her past sexual conduct because in rape prosecutions "the material issue is on the willingness or reluctance of the prosecutrix - an act of the mind"). 181 Susan Estrich, Real Rape 8 (1987). 182 See id. at 8-22 (describing traditional rape definitions, spousal exception, evidentiary rules, and police responses to rape reports); Recent Statutory Developments in the Definition of Forcible Rape, supra note 179, at 1505-07 (describing the "utmost resistance" requirement); see also State v. Terry, 215 A.2d 374, 376 (N.J. Super. Ct. App. Div. 1965) (affirming that, to prove liability for rape, "it must be shown that [the victim] did, in fact, resist the assault"). 183 Kathleen F. Cairney, Addressing Acquaintance Rape: The New Dir