Hopkins v. State, 2017 Ark. App. 273

Maurice Hopkins, a Pine Bluff police officer, was convicted by a jury of second-degree sexual assault and sentenced to 150 months; he appealed on evidentiary and testimonial-grounding errors.
The charged incident arose after Hopkins responded to a separate domestic-disturbance call at an apartment complex; the alleged victim (E.A.) lived nearby and interacted with officers that night.
E.A. testified that Hopkins sexually assaulted her in her apartment; Hopkins testified the encounter was consensual—making credibility central to the case.
Before trial, the State obtained a motion in limine barring cross-examination about whether E.A. had consulted an attorney about a possible civil suit against the city; the trial court granted the motion.
On appeal Hopkins argued the exclusion improperly prevented him from showing E.A.’s potential pecuniary interest and bias; the Court of Appeals found the exclusion prejudicial and reversible.

Issue	Plaintiff's Argument (Hopkins)	Defendant's Argument (State)	Held
Whether trial court erred by excluding evidence that E.A. consulted an attorney about a possible civil suit	Exclusion prevented showing witness bias/pecuniary interest relevant to credibility	Mere consultation (no filed suit) is not sufficient basis for bias cross-examination and implicated privacy concerns	Reversed: exclusion was an abuse of discretion; evidence of consultation about a civil action was admissible and its exclusion was not harmless

Wilson v. State, 289 Ark. 141 (1986) (criminal witness’s pecuniary interest from a civil suit is admissible to show bias)
Edison v. State, 472 S.W.3d 474 (Ark. 2015) (trial court may limit scope of cross-examination once main circumstances of bias are admitted)
Billett v. State, 317 Ark. 346 (1994) (trial court has discretion to limit cross-examination for reasons like harassment or repetition)