Morris v. State, 367 Ark. 406

Summary

The Supreme Court of Arkansas affirmed Willie Edward Morris's convictions for rape and kidnapping. The court held that evidence concerning a separate rape and kidnapping was admissible under Arkansas Rules of Evidence 404(b) to show motive, intent, preparation, plan, and scheme, and that its probative value was not substantially outweighed by unfair prejudice under Rule 403. The court also found no prejudicial error under Arkansas Supreme Court Rule 4-3(h), while Chief Justice Hannah dissented.

Holdings

1. Evidence of Morris's crimes against A.T. was independently relevant and admissible under Arkansas Rule of Evidence 404(b) to prove motive, intent, preparation, plan, and scheme, and not merely to show propensity.
2. The circuit court did not abuse its discretion under Arkansas Rule of Evidence 403 by admitting the A.T. evidence because its probative value on motive, intent, preparation, plan, and scheme was not substantially outweighed by unfair prejudice.
3. The court's review of objections, motions, and requests decided adversely to Morris disclosed no prejudicial error.

Questions Presented

1. Whether evidence concerning Morris's rape and kidnapping of A.T. was independently relevant and admissible under Arkansas Rule of Evidence 404(b) to prove motive, intent, preparation, plan, or scheme rather than propensity.
2. Whether the probative value of the A.T. evidence was substantially outweighed by the danger of unfair prejudice under Arkansas Rule of Evidence 403.
3. Whether the record revealed prejudicial error under Arkansas Supreme Court Rule 4-3(h).

Disposition

affirmed