Summary
The Tenth Court of Appeals of Texas affirmed Rodney Allen Williams’s convictions for aggravated sexual assault of a child and two counts of indecency with a child. The court held that the trial court did not abuse its discretion by excluding cross-examination concerning the complainant’s prior accusation against another person because there was no evidence that the prior accusation was false and therefore probative of motive or bias.
Topics
Practice areas
Questions Presented
- Whether the trial court abused its discretion by excluding evidence of C.F.'s prior accusation against Jarvis and prohibiting Williams from cross-examining C.F. about it.
Holdings
- The trial court did not abuse its discretion by excluding evidence of C.F.'s prior accusation against Jarvis because Williams presented no evidence that the accusation was false, and therefore the evidence was not probative of a pattern of false accusations or of C.F.'s alleged motive to remove people from her mother's life.
Key quotations
“Under an abuse of discretion standard, an appellate court should not disturb the trial court’s decision if the ruling was within the zone of reasonable disagreement.” (4)
“There was no evidence that C.F.’s prior accusation against Jarvis was false.” (7)
Factual background
The complainant, C.F., testified that Williams sexually assaulted her on multiple occasions when she was approximately nine years old while they lived together. Years later, C.F. disclosed the allegations to a school counselor, law enforcement, and a forensic interviewer. Before trial, the court conducted an in camera hearing concerning Williams's request to cross-examine C.F. about a prior sexual-abuse accusation against Jarvis, a later partner of C.F.'s mother; the court excluded the evidence because there was no evidence that the prior accusation was false.
Procedural history
A jury found Williams guilty on all three counts, found the enhancement paragraphs true, and assessed life imprisonment on each count. The trial court sentenced him to life on each count and ordered the sentences to run consecutively. Williams appealed to the Tenth Court of Appeals, which affirmed.