King v. State
564 S.W.3d 563
Ark. Ct. App.2018Background
- Charles was charged with raping AF; a criminal trial challenged evidentiary rulings on appeal.
- The defense sought to admit an order appointing an emergency temporary guardian for AF ("order of appointment").
- The State objected to admitting the order as irrelevant; the circuit court sustained the objection and excluded the document.
- Defense counsel proffered that the order prompted law enforcement to arrest Charles (arrest occurred Oct. 25; the order was entered one day earlier) and argued the order was the sole event leading to the arrest after Oct. 11.
- The appeal contends exclusion was an abuse of discretion because the order made the arrest more likely and was therefore relevant to the case.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of the order of appointment as relevant evidence | The order prompted law enforcement to arrest Charles and so is relevant to how the investigation and arrest occurred | The order is not probative of whether Charles raped AF; arrest motivation is separate from guilt | Court affirmed exclusion: order was not relevant to the central issue of whether Charles raped AF and exclusion was not an abuse of discretion |
Key Cases Cited
- Gillean v. State, 478 S.W.3d 255 (Ark. Ct. App. 2015) (standard for abuse of discretion in evidentiary rulings and definition of relevance under Ark. R. Evid. 401)