Troy Lee Masters v. State of Mississippi, 285 So.3d 192

Troy Lee Masters adopted Cara as a child; Cara testified Masters began sexually abusing her at age 13 and continued into adulthood.
Cara disclosed the abuse in late 2016; recordings and multiple statements to law enforcement were made; Masters gave a post-Miranda statement acknowledging sexual contact and asking for a lawyer.
Masters was indicted on four counts: Count I (sexual battery of a child under 14, alleged 1992), Count II (touching a child for lustful purposes, alleged 1992), Counts III–IV (sexual battery by oral penetration when Cara was 15, alleged Jan 17, 1993–Jan 17, 1994).
The trial court admitted testimony about sexual acts that occurred after Cara reached adulthood as Rule 404(b)/complete-story evidence; Masters declined a jury limiting instruction.
Jury convicted on all counts; trial court imposed concurrent terms (overall 40 years with 16 suspended). Masters’s post-trial motions were denied and he appealed.
On appeal the court affirmed the convictions for Counts I–II but remanded for re-sentencing (sentences exceeded the statutory maxima in effect when the offenses occurred), and reversed-and-rendered as to Counts III–IV because the indictments failed to allege an essential statutory element.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Admissibility of other-bad-acts (adult abuse) evidence	State: testimony was necessary to tell a complete, coherent story and its probative value outweighed prejudice	Masters: evidence was not probative of childhood abuse, was unduly prejudicial under Rule 403/404(b)	Admission was not an abuse of discretion; evidence allowed and no reversible error (defense declined limiting instruction)
2. Legality of sentences for Counts I & II	State: agreed sentences exceeded statutory limits in effect at offense dates	Masters: sentences are illegal/ex post facto because harsher statutes (later) were applied	Sentences for Counts I & II were illegal; remanded for re-sentencing under statutes in effect when offenses occurred
3. Sufficiency/defectiveness of Counts III & IV indictment	State: conceded indictment failed to charge a cognizable crime under the statute(s) in effect	Masters: indictment fatally defective because it did not allege the required element (position of trust/authority after statutory amendment)	Counts III & IV are fatally defective and must be reversed and rendered (convictions vacated)

Shoemaker v. State, 256 So. 3d 604 (Miss. Ct. App. 2018) (Rule 404(b) in child-sex-abuse context and admitting remote bad-acts when probative and coupled with limiting instruction)
Flowers v. State, 773 So. 2d 309 (Miss. 2000) (other-crimes evidence may be admitted to present a complete, coherent story)
Bruce v. State, 35 So. 3d 1236 (Miss. Ct. App. 2010) (other-crimes evidence admissible when it sheds light on motive or forms part of an intimately connected chain of facts)
O’Connor v. State, 120 So. 3d 390 (Miss. 2013) (trial court’s Rule 403 balancing reviewed for abuse of discretion)
Cozart v. State, 226 So. 3d 574 (Miss. 2017) (application of sentencing statute raising ex post facto issue reviewed de novo; sentencing must follow statute in effect at time of offense)
Brown v. State, 890 So. 2d 901 (Miss. 2004) (defendant bears burden to request a limiting instruction for Rule 404(b) evidence)