Jeffries v. State
2014 Ark. 239
| Ark. | 2014Background
- Tracy Dean Jeffries was charged by felony information with two counts of rape for orally and anally assaulting a child under 14 (victim Z.B.).
- Z.B., age ten at trial, testified that Jeffries performed oral sex on him on several occasions and anally penetrated him; Z.B. had not reported earlier because he was scared.
- The State admitted testimony from three other minors (Jeffries’s grandson D.J., niece C.C., and nephew G.B.) under the pedophile exception to Rule 404(b), each describing similar sexual acts while in Jeffries’s care.
- At the close of the State’s case Jeffries moved for a directed verdict (denied), presented no defense witnesses, and rested; the jury convicted on both counts and imposed consecutive life sentences.
- Jeffries appealed, raising (1) sufficiency/directed-verdict error, (2) alleged lowering of the State’s burden of proof during voir dire, and (3) erroneous admission of other-acts evidence under Ark. R. Evid. 404(b).
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Jeffries) | Held |
|---|---|---|---|
| Sufficiency / Directed verdict | Victim testimony (and corroborating similar-acts testimony) was sufficient to prove rape beyond reasonable doubt | Z.B. was too young to provide credible evidence; insufficient proof of penetration | Affirmed — victim’s uncorroborated testimony describing penetration can constitute substantial evidence; jury credibility determination upheld |
| Voir dire / Burden of proof | Any voir dire misstatements were corrected by court and final jury instructions correctly stated burden beyond a reasonable doubt | State impermissibly lowered its burden during voir dire, depriving fair trial | Affirmed — court admonished panel, read correct burden, no abuse of discretion in voir dire conduct |
| Admission of prior acts (Rule 404(b) / pedophile exception) | Prior-act testimony was admissible under pedophile exception to show proclivity, method, and intimate relationship with children | Prior-act testimony was irrelevant and unduly prejudicial | Affirmed — testimony sufficiently similar, involved intimate relationships, probative value outweighed prejudice; no abuse of discretion |
| Remoteness / Rule 403 balancing | Prior acts were not unduly remote and were probative of depraved sexual instinct and modus operandi | Prior acts were prejudicial and remote | Affirmed — trial court properly exercised discretion on remoteness and Rule 403 balance |
Key Cases Cited
- Jones v. State, 300 Ark. 565 (victim’s uncorroborated testimony may support rape conviction)
- Hall v. State, 315 Ark. 385 (voir dire procedure and trial-court discretion)
- Flanery v. State, 362 Ark. 311 (pedophile exception to Rule 404(b))
- Strong v. State, 372 Ark. 404 (Rule 404(b) admission reviewed for abuse of discretion)
- White v. State, 367 Ark. 595 (similarity and intimate-relationship requirements for pedophile exception)
- Nelson v. State, 365 Ark. 314 (remoteness and trial-court discretion on other-acts evidence)
- Brown v. State, 2012 Ark. 399 (Rule 403 balancing and deference to trial court)
- Williamson v. State, 2009 Ark. 568 (sufficiency challenge preserved when defense rests without presenting evidence)
- Smoak v. State, 2011 Ark. 529 (standard of review for directed-verdict/sufficiency challenges)