Young v. State
106 So. 3d 775
| Miss. | 2012Background
- Johnny Young was convicted in Union County Circuit Court on three counts of sexual battery of his minor daughter Cindy, receiving three concurrent life sentences.
- The Court of Appeals affirmed; certiorari granted to review two issues.
- Evidence showed prior sexual misconduct: twenty-years-earlier act involving Young and his half-sister Anna; admitted under Rule 404(b) with limiting instruction.
- Nurse Elizabeth Thomas, a sexual-assault nurse examiner (SANE), testified about Cindy’s injuries observed during exam; the trial court limited her testimony to noncausation observations.
- The Supreme Court affirmed the trial court’s admission of the prior-bad-acts evidence and Thomas’s testimony within stated limitations; some concurring/dissenting opinions followed.
- Concluding, the judgments of the circuit court and Court of Appeals were affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of prior sexual misconduct under Rule 404(b) | Young argues the 404(b) evidence was too remote and prejudicial | Young contends evidence served improper propensity purpose | Admissible for noncharacter purposes; not abusively admitted. |
| SANE testimony on causation by Nurse Thomas | Thomas testified to medical causation beyond disclosed scope | Thomas qualified within limitations; allowed to testify about observations | Thomas qualified; testimony within limitations and not a medical-diagnosis causation opinion. |
Key Cases Cited
- Gore v. State, 37 So.3d 1178 (Miss. 2010) (prior-sexual-misconduct evidence admissible for noncharacter purposes when similar methods are shown)
- Green v. State, 89 So.3d 543 (Miss. 2012) (similarities in prior acts support Rule 404(b) admissibility)
- Derouen v. State, 994 So.2d 748 (Miss. 2008) (requires 404(b) evidence filtered through 403 with limiting instruction)
- Vaughn v. Miss. Baptist Med. Ctr., 20 So.3d 645 (Miss. 2009) (nurse-causation limitations; distinguishes from medical causation rules)
- Richardson v. Methodist Hosp. of Hattiesburg, Inc., 807 So.2d 1244 (Miss. 2002) (nurse not qualified to testify to medical causation; limits on nursing expert testimony)
- Harden v. State, 59 So.3d 594 (Miss. 2011) (SANE testimony context; supports allowed noncausation observations)