Vance v. State, 2011 Ark. 392

State charged Yance with one count of rape of his fourteen-year-old daughter B.V.; conviction and twenty-year sentence affirmed.
B.V. testified to two separate acts of sexual intercourse with appellant during overnight visits after consuming alcohol in May and October 2008, plus a later instance involving oral sex and viewing pornography.
B.V. described vaginal bleeding after both encounters and testified she did not remember details between changes of clothing and waking.
Dr. Jones testified his examination showed findings consistent with vaginal penetration; corroborating testimony linked appellant to alcohol purchases on relevant dates.
Defendant testified denying giving B.V. alcohol or molesting her; he moved for directed verdict, which the court denied.
Pretrial motions sought admission of rape-shield evidence about B.V. and K.W.’s alleged relationship; the circuit court denied these motions as prejudicial and irrelevant.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to prove rape	Yance argues the evidence fails to prove penetration.	Yance contends lack of corroboration beyond her testimony.	Substantial evidence supports penetration by routine testimony and medical findings.
Admissibility of rape-shield evidence	State asserts evidence shows bias and relevance to defense.	Yance argues such evidence is admissible to impeach credibility.	Circuit court did not abuse discretion; evidence was collateral and prejudicial under rape-shield statute.
Confrontation Clause preservation	Yance contends exclusion violated his Confrontation Clause rights.	Yance maintains the exclusion bears on his defense.	Issue not preserved for review; court declines to address Confrontation Clause argument.

Brown v. State, 374 Ark. 341, 288 S.W.3d 226 (2008) (un corroborated victim testimony may support conviction)
Townsend v. State, 366 Ark. 152, 233 S.W.3d 680 (2006) (rape-shield evidence collateral when consent not at issue)
M.M. v. State, 350 Ark. 328, 88 S.W.3d 406 (2002) (rape-shield limits on evidence of victim's prior sexual conduct)
Evans v. State, 317 Ark. 532, 878 S.W.2d 750 (1994) (rape-shield relevance and collateral considerations)
Beed v. State, 271 Ark. 526, 609 S.W.2d 898 (1980) (trial court discretion in evidentiary rulings)
Thomas v. State, 266 Ark. 162, 583 S.W.2d 32 (1979) (credibility and jury resolution of witness testimony)
Holmes v. South Carolina, 547 U.S. 319, 126 S.Ct. 1727, 164 L.Ed.2d 503 (2006) (preservation of objections; Confrontation Clause considerations)