State of Missouri v. Shane A. Vorhees

Summary

The Supreme Court of Missouri held that evidence of a defendant's prior sexual misconduct may not be admitted solely to corroborate an alleged victim's testimony under a signature modus operandi theory. The court concluded that such evidence is propensity evidence and violates the Missouri Constitution's guarantee that a defendant be tried only for the charged offense. The judgment was reversed and the case remanded for a new trial.

Holdings

1. Evidence of prior bad acts, regardless of how similar or distinctive those acts are, may not be admitted solely to corroborate an alleged victim's testimony because that use is propensity evidence and violates the Missouri Constitution's guarantee that a defendant be tried only for the offense charged.
2. Missouri's signature modus operandi corroboration exception is invalid because it is merely propensity evidence masquerading as an identity exception.
3. The trial court erred by admitting J.W.'s testimony concerning prior uncharged sexual conduct to corroborate S.W.'s testimony.

Questions Presented

1. Whether evidence of prior uncharged sexual conduct may be admitted solely to corroborate an alleged victim's testimony that the charged sexual offense occurred.
2. Whether Missouri's signature modus operandi corroboration exception to the general prohibition on prior-bad-acts evidence is constitutional.
3. Whether the trial court erred by admitting the prior-act evidence under section 566.025, RSMo 2000.

Disposition

reversed_and_remanded