State v. Williams, 548 S.W.3d 275

Background

Travis Williams was convicted by a jury of three counts of first-degree statutory sodomy for repeatedly sexually abusing his stepdaughter between 2008 and 2013; he was sentenced as a predatory sexual offender to three concurrent life terms with no parole for 50 years.
Williams had a prior 1996 guilty plea for first-degree statutory sodomy (inserting his thumb in a 12‑year‑old girl); the State sought to admit that conviction pretrial under Mo. Const. art. I, § 18(c) as propensity/corroborative evidence.
The trial court granted the State’s motion but limited proof to a stipulation of the prior plea; the stipulation was read to the jury over Williams’s continuing objection.
Williams raised facial and as‑applied constitutional challenges on appeal, arguing art. I, § 18(c) (adopted 2014) violated due process and the right to a jury trial, and that the trial court erred in admitting the prior conviction without an express on‑the‑record balancing and because prejudice outweighed probative value.
The Missouri Supreme Court reviewed: (1) whether art. I, § 18(c) is facially unconstitutional; (2) whether a trial court must make an express finding that probative value is not substantially outweighed by unfair prejudice; and (3) whether the court abused its discretion admitting Williams’s 1996 conviction.

Issues

Issue	Plaintiff's Argument (Williams)	Defendant's Argument (State)	Held
Facial due process challenge to art. I, § 18(c)	The amendment authorizes propensity evidence in the State’s case‑in‑chief and thus violates due process/fundamental fairness.	Art. I, § 18(c) mirrors Fed. R. Evid. 414/403; historical practice and Rule 403 safeguards permit the amendment as constitutional.	Rejected — art. I, § 18(c) is not facially unconstitutional; Rule 403‑style balancing cures due process concerns.
Requirement of an express on‑the‑record finding under § 18(c)	Trial courts must make an express statement that probative value is not substantially outweighed by unfair prejudice before admitting propensity evidence.	The text of § 18(c) does not mandate a magic‑word finding; implicit on‑record balancing suffices if appellate review can discern the reasoning.	Rejected — no constitutional or textual requirement for an express finding so long as the record shows the court engaged in the required balancing.
Evidentiary abuse of discretion in admitting Williams’s 1996 conviction	The prior conviction’s prejudicial effect substantially outweighed its probative value and it should have been excluded.	The prior conviction was highly similar, reasonably proximate in time, proven by plea/stipulation, the State had a real need, and the court limited presentation to a stipulation—so prejudice did not substantially outweigh probative value.	Rejected — no abuse of discretion; balancing factors supported admission and the court mitigated prejudice (stipulation, limited presentation).
Jury trial right claim	Admission of propensity evidence under § 18(c) undermines the jury‑trial protections (not separately argued).	Claim duplicates due process challenge and was not separately developed; same analysis applies.	Rejected — no separate basis shown beyond due process ruling.

Key Cases Cited

Michelson v. United States, 335 U.S. 469 (1948) (historic articulation of the common‑law rule excluding character/propensity evidence in criminal prosecutions).
Montana v. Egelhoff, 518 U.S. 37 (1996) (due process test: violation only if rule offends principles deeply rooted in traditions and conscience).
Huddleston v. United States, 485 U.S. 681 (1988) (prior‑act evidence is relevant only if jury can reasonably conclude the act occurred and defendant was actor).
Old Chief v. United States, 519 U.S. 172 (1997) (court must consider less prejudicial means of proving prior convictions and balance probative value against prejudice).
United States v. LeMay, 260 F.3d 1018 (9th Cir. 2001) (upholding Fed. R. Evid. 414 against facial due process challenge and emphasizing Rule 403 balancing protections).
United States v. Castillo, 140 F.3d 874 (10th Cir. 1998) (similar holding that Rule 403 cures due process concerns with propensity evidence rules).
State v. Ellison, 239 S.W.3d 603 (Mo. banc 2007) (prior Missouri precedent that art. I, § 18(c) aimed to abrogate).
State v. Prince, 534 S.W.3d 813 (Mo. banc 2017) (standard of review for evidentiary rulings; abuse of discretion review).