State v. Prince, 534 S.W.3d 813

Background

Defendant Jordan L. Prince (formerly adjudicated in Idaho at age 15 for lewd and lascivious conduct with a six‑year‑old niece) was tried in Missouri for first‑degree murder, felony child abuse, and forcible sodomy involving a four‑month‑old victim who died from strangulation after sustaining severe anal and other injuries.
Physical and forensic evidence tied Prince to the scene: his and the infant’s blood on the couch quilt, and he was the last person to see the child alive and excluded other suspects in police interviews.
Investigators recovered pornography and incest/pedophilia‑related internet activity on Prince’s phone and computer (some accessed up to the morning of the child’s death), and texts between Prince and the victim’s mother discussing sexual contact with underage girls.
The State introduced Prince’s Idaho juvenile adjudication (official record read to the jury) and videotaped interrogation statements in which Prince referenced that adjudication and offered accidental explanations for the injuries.
Prince was convicted by a jury; he waived jury sentencing and received consecutive life sentences. On appeal he challenged (1) admission of his juvenile adjudication and (2) admission of pornographic/internet evidence as not logically or legally relevant or unduly prejudicial.

Issues

Issue	Prince's Argument	State's Argument	Held
Admissibility of Idaho juvenile adjudication — logical relevance	Prior juvenile adjudication was too remote, dissimilar, and not a "criminal" conviction so not logically relevant	Prior acts against young females in a family‑like setting tend to make propensity and identity more probable; logical relevance is a low threshold	Admitted — court found the juvenile adjudication was logically relevant (similar victims, access, and conduct)
Admissibility of Idaho juvenile adjudication — legal relevance (prejudice vs. probative value)	The nine‑year gap and differences in victims made the prior act unfairly prejudicial and too remote	Similarity of conduct and victim profile, plus significant corroborating evidence, meant probative value outweighed prejudice	Admitted — probative value not substantially outweighed by unfair prejudice; discretion to admit upheld
Admission of pornography and internet searches	Evidence was improper character evidence and inflammatory; prejudicial	Evidence provided context, showed continued sexual interest in incest/young girls, and negated accident claims; not merely "bad character" proof	Admitted — court held evidence relevant to motive, absence of mistake, and context; any prejudice was not outcome‑determinative
Cumulative prejudice and sufficiency of other evidence	Admission of all prior bad‑act and porn evidence deprived Prince of a fair trial	Significant independent forensic and testimonial evidence supported conviction; no reasonable probability admission affected verdict	No reversible error — admission did not deprive Prince of a fair trial

Key Cases Cited

State v. Blurton, 484 S.W.3d 758 (Mo. banc 2016) (standard for relevancy and circuit court discretion)
State v. Primm, 347 S.W.3d 66 (Mo. banc 2011) (exceptions permitting otherwise inadmissible misconduct evidence)
State v. Anderson, 306 S.W.3d 529 (Mo. banc 2010) (legal relevance requires probative value vs. prejudice balancing)
State v. Shaw, 847 S.W.2d 768 (Mo. banc 1993) (remoteness affects weight and prejudice analysis)
United States v. Emmert, 825 F.3d 906 (8th Cir. 2016) (prior sexual offenses many years earlier may be admissible when similar)
United States v. LeMay, 260 F.3d 1018 (9th Cir. 2001) (admission of prior sexual conduct committed years earlier can be permissible when probative)