dissenting.
The court bases its reversal of Conrad Worthy’s conviction on the fact that the State’s references at trial to “Chris” and the alleged Barrow rape incident “had the effect of elevating that incident to a level of importance it would not normally have had.”1 Thus, according to the court, it was the State’s conduct during trial in asking questions and making arguments about the Barrow rape that rendered Chris’s testimony about the falsity of that rape charge admissible. But the court does not challenge the correctness of the trial judge’s pretrial decision to exclude Chris’s testimony. And because Worthy never renewed his request to call Chris as a witness during trial on the ground that the State had “opened the door,” the trial judge never had an opportunity to consider the theory of admissibility now relied on by the court. I therefore disagree with the court’s view that the trial judge committed any error in failing to allow Chris to testify and would affirm the conviction.
In his pre-trial motion, Worthy requested permission to call Chris to testify that T.J.S. had falsely accused him of rape and that T.J.S. had consented to have sex with him. But, as the court properly points out, AS 12.45.045(a) expressly forbids evidence' con*777cerning the prior sexual conduct of an alleged sexual assault victim.2 And • as the court of appeals held in Covington v. State,3 prior false allegations of sexual assault are not admissible to discredit the, victim’s current allegations unless the proponent of the evidence meets the threshold burden of establishing the falsity of the past reports.4 In Covington the court of appeals decided that such evidence would only be permissible “where the charges somehow had been disproved or where the witness had conceded their falsity.”5
In this case, because Worthy’s pre-trial offer of proof did not meet the Covington standard, the superior court properly denied his request to call Chris. And the court today does not disagree that the superior court’s Covington ruling was correct. Thus, on the only occasion when Worthy did request permission to call Chris — before trial began and before the Barrow rape became “independently relevant”6 — the superior court properly ruled to exclude such testimony. This pre-trial decision to exclude Chris’s testimony therefore cannot be ■ a basis for reversal on appeal.
The court excuses Worthy’s failure to renew his request to call Chris by reasoning that Worthy’s theory of relevance “never changed.”7 But it is the State’s conduct in making the Barrow rape incident a “central part” of its case at trial that forms the basis for the court’s reversal of the conviction.8 Because Worthy never made the argument upon which the court now relies, the superior court had no opportunity to reconsider its initial ruling on this theory of admissibility.
The court’s opinion implies that because the State opened the door to Chris’s testimony, the trial judge should have revised her order sua sponte and invited Worthy to call Chris as a witness. But in the vast majority of trials, the judge will issue some form of protective order precluding the introduction of certain evidence. And it is not unusual for a party to render the previously excluded evidence relevant and admissible by some action of its own during trial. In my view it is not appropriate to hold the trial court responsible for identifying new theories of admissibility and pointing those theories out to the parties during the course of a trial. Indeed, lawyers may have strategic reasons for letting the opportunity to reargue a point pass.
I therefore believe that Worthy waived his argument that the State improperly “opened the door” to the Barrow rape because he did not specifically object to the State’s conduct during trial or renew his request to call Chris. And although the court observes that the State did not argue waiver in this appeal,9 we can affirm on any grounds that are supported by the record.10
Moreover, in a case -similar to the one before us, the court of appeals properly affirmed the conviction of a defendant who attempted to raise on appeal a new theory for admitting evidence excluded at trial. In Dyer v. State,11 the defendant initially sought to cross-examine a witness concerning the witness’s pending criminal charges in order to show bias.12 The court properly granted a protective order that prevented the defen*778dant from doing so.13 But on appeal the defendant argued that he should have been able to introduce the pending charges because the State “placed evidence of [the witness’s] character for peacefulness in issue.”14 The defendant never asserted those grounds for admitting the evidence in the trial court, however, nor did he renew his request to cross-examine the witness on the pending charges. The defendant only asked to use the evidence to establish bias, a request that the trial court properly denied.15 The court of appeals accordingly held that “since no application was made to the trial judge on these [new] grounds, we conclude that [the defendant] may not now argue different grounds for admitting the evidence on appeal.”16 Similarly here, because Worthy never renewed his request to call Chris under the theory that the prosecution had “opened the door,” or that the Barrow rape incident had taken on “independent relevance,” he should not be allowed to argue those grounds for the first time on appeal.17
Because Worthy never renewed his request to call Chris as a witness, the trial court had no opportunity to revisit the issue. Although I do not disagree with the court that the State “opened the door” to evidence of the victim’s allegedly false report of the Barrow rape, it was incumbent upon Worthy to renew his request to call Chris. This court will reverse a decision only where the court below commits some error, and in this case, the superior court’s only ruling on this matter was proper. In failing to object to the State’s conduct, Worthy did not give the trial court an opportunity to remedy the State’s conduct in opening the door to details of the Barrow rape incident.18 For these reasons, I disagree with the court’s decision and would affirm the conviction.
APPENDIX
References to “Barrow Rape” by Prosecution
Prosecution’s Opening Statement:
While Mr. Worthy is [sexually assaulting T.J.S.]. He starts saying some very cruel things to her.
[T.J.S.], in April of 1994, was sexually assaulted by a co-worker, while she was working for MarkAir in Barrow. It was a difficult time for her. It was something that stayed with her. It was something that she and Mr. Worthy had talked about. The person that she believed had done that assault on her in Barrow, was a fellow named Chris. [It] wasn’t proven at any point in time. It wasn’t brought to this stage. But the person was named Chris.
And Mr. Worthy, as he sitting astride of this woman, or lifting her up, he says, “Think of me as Chris. I think this is *779what you wanted Chris to do up in Barrow.”
He said things to her, to let her know how she ought to feel about this circumstance that she found herself in.
“This is like what Chris did to you.”
This is unpleasant to [T.J.S.]. This is hurtful to [T.J.S.].
[[Image here]]
And as things progress, you will also hear that Mr. Worthy not only mentioned, brings up, uses this name of “Chris,” and this incident in Barrow, as a means of, at least, verbally assaulting, or somehow communicating what his intention is that morning. He calls her a lot of other names.
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After she’s been called a lot of names. Not necessarily every name in the book, but she’s been called a lot of names. She’s been scared by the cruel remarks about the former sexual assault. She’s concerned that he is so out of control, that she doesn’t know what he is going to do next.
[[Image here]]
In April of ’94, a terrible thing happened in Barrow. She was sexually assaulted. It occurred after a party. It was a terrible thing for her. She left the Barrow posting, and was transferred to St. Mary’s.
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After that [telephone conversation between T.J.S. and Worthy following the assault], in which [Worthy] basically says, “It wasn’t me, it must have been this Brian guy. Maybe it was Chris. Maybe it was the guy up north. You’re havin’ [sic] a bad dream about all this stuff.”
Prosecution’s Direct Examination of Officer Kevin Bradley Mitchell:
[T.J.S.] said ... And while [Worthy] was [sexually assaulting her], she indicated to me that he had made statements to the effect of — while he was doing this he said, “Just think of me as Chris.”
[T.J.S.] had indicated at that point that she had been sexually assaulted prior — I’m not sure of the time frame, but I believe it was about a year prior, at the place where she had worked up in Barrow, and that incident was being criminally investigated. But she had come back to Mr. Worthy, her boyfriend, and told him about the incident, and told him what happened, and apparently they had gone through some trauma of that.
And during that incident, while she was being held down and he was inserting his fingers into her vagina, he was telling her, “Just think of me as Chris. Just think of me as Chris,” as he was doing that.
Prosecution’s Direct Examination of T.J.S.:
Q: You ended that Barrow posting when?
A: April.
Q: Why?
A: Because of an incident with another employee.
Q: Was this a fellow named Chris?
A: Yes.
Q: Was this an incident that was sexual in nature?
A: Yes.
Q: Against your will?
A: Yes.
Q: Investigated by the police?
A: Yes.
Q: You didn’t want to work there anymore?
A: No.
Q: Did you continue to work for Mark-Air?
A: Yes.
Q: In this incident that involved this fellow named Chris, you said he was a co-worker?
A: Yes.
Q: Was this an incident that involved genital intercourse?
A: Yes.
Q: Any other kind of intercourse or penetration?
A: No.
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Q: You said you ended up somehow— when you were over by the copy machine, what happened?
*780A: Um, there was some struggle, I was on the .floor on my back, um, he was saying things. I was trying to tell him not to do this.... He was still calling me cruel names, and about then is when he started saying things like, “Think of me as Chris.”
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Q: When your pantyhose were ripped, while you were on the floor, you said he was saying things about, “Think of me as Chris?”
A: Yes..
Q: Chris was the fellow that you talked about in Barrow?
A: Yes.
Q: Did you talk to Mr. Worthy about Chris?
A: Yes.
Q: Had you communicated to Mr. Worthy that Chris was an unpleasant memory for you?
A: Yes.
Q: How did you feel when Mr. Worthy said things like, “Think of me as Chris?”
A: Very hurt.
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Q: At some point did he make actual contact with your genitals?
A: Yes.
Q: How did that come about? Describe that for us?
A: He was holding me down saying the things about Chris, and calling me cruel names, and he had basically, all of me pinned down somehow.
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Q: Did Mr. Worthy say he wanted you to do anything during this encounter?
A: To think of him as Chris; to use my [self-defense] training. That’s the only things I remember.
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Q: Why weren’t you going to report the crime? (Pause)
A: Because — because I didn’t want to— (pause). — I didn’t really want — I— (pause) — -I didn’t want to.
Q: Was there anything about your relationship with Mr. Worthy that caused you not to want to?
A: I didn’t want him to get into trouble.
[[Image here]]
Q: Had you been through a police investigation in the past?
A: There — at that point, there was still one going on in Barrow.
Q: Was it a pleasant experience for you?
A: No.
Q: Was it something that you thought, “I’ll go report this crime, I’m looking forward to nailing him for this?”
A: No.
Q: So you called the police?
A: Yes.
Prosecution’s Redirect Examination of T.J.S.:
Q: With regard to the Barrow incident, did you want to be posted in Barrow?
A: Yes. I had been trying to get the position in Barrow for a long time, and I had just started a new job in Anchorage, when I got the news that I go it, I was really happy that I had gone out there.
Q: So then we can understand, this happened after a party with co-workers?
A: Yeah. The way that the shifts work, because we’re eight days on, six days off. There is one night that, basically, everybody is there, and so we would get together on that night, over at some friends house and have a couple drinks, and then go home and go to sleep, and some of us would go to work the next day, and some of us would fly back into town, or wherever we were going.
Q: What were you on? Were you going to work the next day, or were you going home?
A: That was my shift, I was going to work.
Q: This fellow, whose name we now know is, Chris. Was he on shift, or was he going home?
*781A: He was going home.
Q: Do you know when you left this party?
A: I know it was a few hours before everyone else, because I couldn’t get a ride at first, (indiscernible — unclear) finally said, “Okay, I’ll leave and I’ll take you home,” probably around midnight, because I like to get enough sleep before I go to work the next day, especially when I’m working a 10-hour day.
Q: And so a few hours later, you are awakened from your sleep?
A: Yes.
Q: Did you share a room with anybody?
A: No.
Q: And this fellow, did he admit to coming into your room?
A: He ...
Ms. Tatter: Objection. Hearsay.
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Q: We were talking about what happened in Barrow in April of 1994. Did you tell Mr. Worthy about that?
A: Yes, I did.
Q: Did he know that you were making follow-up telephone calls?
A: Yes, he did.
Q: Did he encourage you on that score?
A: Yeah, I think so.
Q: Did Mr. Worthy take you seriously about what had happened up in Barrow?
(Pause)
A: Sometimes. Most of the time he didn’t. Most of the time he said that it was something that I caused — something that I tried to do.
Q: And [T.J.S.], did you tell Mr. Worthy that this was an incident in which you did not consent?
A: Yes, I did.
Q: Did you tell Mr. Worthy, or communicate to Mr.. Worthy in any way, that this was some kind of drunken orgy?
A: No.
Q: During the reported conversation with this person named Chris, did he admit being in your room?
A: During the wire he did.
Q: Did you engage in a telephone conversation that was recorded by the police, with Mr. Worthy?
A: Yes, I did.
Prosecution’s Closing Argument:
And then finally, ladies' and gentlemen, the defendant tells Detective Herrick that they talked about Chris from Barrow. Ladies and gentlemen, this is a. real interesting piece of information. Why are we bringing up Chris from barrow if this is not sexual in nature. Everything about Chris from Barrow is sexual.
We hear from Sue Ellen Tatter in opening that they’re going to prove that this is a drunken orgy. What we heard from Conrad Worthy was it was a very sad and humiliating and devastating thing for both of them. ,And “I didn’t really understand wasn’t pressing it, I didn’t understand why she wasn’t calling the cops every day, calling the district attorney’s office, pressing this home, pressing this home.” He wasn’t being particularly sensitive to [T.J.S.’s] needs in that situation, but we all acknowledge beyond a shadow of a doubt that that was a sexual assault and he’s talking about this as he’s doing these things to [T.J.S.].
Ladies and gentlemen, why bring up Chris if you’re not talking about sex. If we’re not dealing with what the law calls sexual penetration.
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He admits to Detective Herrick that she was defending herself. He says that his fingers may have gone in her vagina. And you, again, you get to decide whether that can happen inadvertently, especially under the circumstances urider which this would admittedly perform. Because he said “I talked about Chris from Barrow and that was a sexual matter.”
. Op. at 774.
. See Op. at 774 (citing AS 12.45.045(a) ("In prosecutions for the crimes of sexual assault in any degree, ... evidence of the complaining witness’ previous sexual conduct may not be admitted nor may reference be made to it in the presence of the jury....”)).
. 703 P.2d 436, 442 (Alaska App.1985).
. See id.; Johnson v. State, 889 P.2d 1076, 1078 (Alaska App.1995) (recognizing that "we have consistently held” that a party who wishes to introduce evidence of past false reports of sexual assault "bears the threshold burden of establishing the falsity of the past reports”).
. Covington, 703 P.2d at 442.
. Op. at 774.
. Op. at 775.
. Op. at 774.
. See Op. at 775.
. See Mackie v. Chizmar, 965 P.2d 1202, 1207 n. 4 (Alaska 1998); Dixon v. Dixon, 747 P.2d 1169, 1175 n. 5 (Alaska 1987).
. 666 P.2d 438 (Alaska App.1983).
. See id. at 450.
. See id.
. Id.
. See id.
. Id. at 451; see also Jones v. State, 576 P.2d 997, 1001 (Alaska 1978) ("Having specified a particular purpose for the offer, Jones is not in a position to now claim error because the evidence might have been admissible on other grounds.").
. See, e.g., Trobough v. French, 803 P.2d 384, 385 (Alaska 1990) (where a litigant failed to object to her adversary’s conduct during trial and never requested a mistrial, the trial court abused its discretion in granting the new trial because the plaintiff did not "formally object to the questioned acts at the time they were committed"); Moss v. State, 620 P.2d 674, 677 (Alaska 1980) (holding that it was "incumbent upon counsel to renew his attempt to obtain the witness’ testimony," and that by failing to do so, defendant waived his request); Petersen v. State, 838 P.2d 812, 816 (Alaska App.1992) (Bryner, C.J.) (because defendant failed to renew his request for severance, the trial court's failure to order severance sua sponte did not amount to plain error).
.The purpose of the rule requiring parties to object formally to errors during trial is "to facilitate the administration of justice by permitting the trial judge to obviate any error that might otherwise occur if no objection were made, by permitting him to correct at the earliest possible time any error that may have occurred, and by allowing the adverse party the opportunity to remedy, if possible, any defect in his method of proof.” Harned v. Dura Corp., 665 P.2d 5, 9 n. 11 (quoting Thomson v. Wheeler Constr. Co., 385 P.2d 111, 115 (Alaska 1963)); see also Williams v. State, 629 P.2d 54, 59 (Alaska 1981) (purpose is "to require errors to be brought to the attention of the trial court in time for their correction so as to avoid the inconvenience and expense of a new trial”) (quoting Dimmick v. State, 449 P.2d 774, 776 (Alaska 1969)).