Woods v. State, 431 S.W.3d 343

Arkansas Court of Appeals affirmed Woods's conviction for raping his minor stepdaughter, with a forty-year sentence.
Woods challenged admission of his 1998 Missouri child-molestation conviction under Rule 404(b)'s pedophile exception.
The State relied on similar-act evidence to show Woods's depraved sexual propensity.
C.N. testified that Woods repeatedly raped her when she was 12–13; K.L. testified to prior abuse by Woods.
Trial court admitted 1998 conviction under 404(b); the court gave a sua sponte cautionary instruction after K.L.'s testimony.
Woods argued insufficiency of evidence, and the State argued the prior acts supported the rape conviction; the court rejected both appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of 1998 Missouri conviction under 404(b) pedophile exception	Woods claims dissimilar facts and time make admission improper	State asserts similarity and time proximity satisfy pedophile exception	Admission affirmed under pedophile exception
Sufficiency of the evidence for rape	Without 404(b) evidence, there is insufficient corroboration	C.N.'s testimony alone can sustain rape conviction	Sufficient evidence supports rape conviction

Breeden v. State, 2013 Ark. 145 (Ark. 2013) (un corroborated rape victim testimony can sustain conviction; no scientific evidence required)
Craigg v. State, 2012 Ark. 387 (Ark. 2012) (pedophile exception admissible even with long-ago prior for similar acts)
Lamb v. State, 2008 Ark. 379 (Ark. 2008) (previous acts with children not too remote in time under 404(b))
Ryan v. State, 1990 Ark. App. 196 (Ark. App. 1990) (consider all evidence when reviewing sufficiency, including admissible and inadmissible)
Benson v. State, 2004 Ark. 43 (Ark. 2004) (lack of physical findings not conclusive on rape)