Matthew Dennis v. State of Arkansas
2025 Ark. App. 410
Ark. Ct. App.2025Background
- Defendant Matthew Dennis charged with second-degree sexual assault of a minor for sexual contact with MC, a 14-year-old girl.
- MC and her family moved into Dennis’s home during COVID; Dennis was a longtime family friend and called “Uncle Matt.”
- MC slept on a sectional sofa in the living room with Dennis; her parents later moved to a trailer on his property.
- Dennis supervised MC’s schooling (she was homeschooled) and taught her to drive and operate heavy equipment; family entrusted him with her care.
- MC testified Dennis repeatedly touched her genitals through clothing, inserted a finger, and made statements about marrying her; Dennis admitted inappropriate sexual contact in an interview.
- Trial court denied directed verdict; jury convicted. Dennis appealed only the sufficiency of evidence that he was a guardian/temporary caretaker/person in a position of trust or authority.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence sufficed to prove Dennis was a guardian, temporary caretaker, or in a position of trust/authority over MC | State: Dennis was a trusted family friend who provided housing, supervision, and caretaking functions, meeting statutory categories | Dennis: Insufficient evidence that he occupied the special relationship required by statute | Affirmed: Substantial evidence supported that Dennis was at least a temporary caretaker/position of trust or authority |
Key Cases Cited
- Harvey v. State, 700 S.W.3d 904 (Ark. App. 2024) (standard for reviewing denial of directed verdict and definition of substantial evidence)
- Nelson v. State, 384 S.W.3d 534 (Ark. 2011) (interpretation of trust/authority relationship in sexual-offense context)
- Bowker v. State, 214 S.W.3d 243 (Ark. 2005) (application of statutory categories for persons in position of trust or authority)