Daryl Brent McDaniel v. State of Arkansas

2025 Ark. App. 129, 708 S.W.3d 386
CourtCourt of Appeals of Arkansas
DecidedFebruary 26, 2025
StatusPublished
Cited by1 cases

This text of 2025 Ark. App. 129 (Daryl Brent McDaniel v. State of Arkansas) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Daryl Brent McDaniel v. State of Arkansas, 2025 Ark. App. 129, 708 S.W.3d 386 (Ark. Ct. App. 2025).

Opinion

Cite as 2025 Ark. App. 129 ARKANSAS COURT OF APPEALS DIVISION I No. CR-24-221

Opinion Delivered February 26, 2025

DARYL BRENT MCDANIEL APPEAL FROM THE MILLER APPELLANT COUNTY CIRCUIT COURT [NO. 46CR-21-227] V. HONORABLE BRENT HALTOM, JUDGE STATE OF ARKANSAS APPELLEE AFFIRMED

KENNETH S. HIXSON, Judge

Appellant Daryl Brent McDaniel was convicted in a jury trial of three counts of rape,

four counts of second-degree sexual assault, and one count of sexual indecency with a child.

These offenses were committed by McDaniel against his then nine- to ten-year-old

stepdaughter, Minor Victim (MV), during the years 2015–2016. For these convictions,

McDaniel was sentenced to consecutive prison sentences totaling 205 years in the Arkansas

Division of Correction.

On appeal from his convictions, McDaniel raises two arguments. First, he argues that

the trial court erred in denying his request to order the State to specifically identify which

testimony was associated with which count either during or at the conclusion of MV’s

testimony. Next, McDaniel argues that the trial court erred in permitting forensic interviewer Kristi Kirkwood to testify about how child-forensic interviews are conducted, the

typical stages of disclosure, and the reasons why a child may recant. We affirm.1

On September 22, 2012, the State filed an amended criminal information charging

McDaniel with three counts of rape, four counts of second-degree sexual assault, and one

count of sexual indecency with a child committed against MV during the years 2015–2016.

As charged, these offenses require proof of the following elements.

Pursuant to Ark. Code Ann. § 5-14-103(a)(3)(A) (Repl. 2024), a person commits rape

if he engages in sexual intercourse or deviate sexual activity with another person who is less

than fourteen years of age. “Sexual intercourse” means penetration, however slight, of the

labia majora by a penis. Ark. Code Ann. § 5-14-101(13) (Repl. 2024). “Deviate sexual

activity” means any act of sexual gratification involving (A) The penetration, however slight,

of the anus or mouth of a person by the penis of another person; or (B) The penetration,

however slight, of the labia majora or anus of a person by any body member or foreign

instrument manipulated by another person. Ark. Code Ann. § 5-14-101(1). Pursuant to

Ark. Code Ann. § 5-14-125(a)(3) (Repl. 2024), a person commits second-degree sexual assault

if the person, being eighteen years of age or older, engages in sexual contact with another

person who is less than fourteen years of age. “Sexual contact” means an act of sexual

gratification involving the touching, directly or through clothing, of the sex organs, buttocks,

1 On April 8, 2024, McDaniel’s counsel filed a motion seeking the recusal or disqualification of Judge Stephanie Potter Barrett. The motion was passed to the panel for consideration with the submission of the case. Because Judge Barrett is not on this panel, the motion is denied as moot.

2 or anus of a person or the breast of a female. Ark. Code Ann. § 5-14-101(12)(A). Pursuant

to Ark. Code Ann. § 5-14-110(a)(2) (Repl. 2024), a person commits sexual indecency with a

child if, being eighteen years of age or older, and with the purpose to arouse or gratify a

sexual desire of himself, the person purposely exposes his or her sex organs to another person

who is less than fifteen years of age.

At a pretrial hearing, McDaniel noted that he was charged with multiple sex crimes

and moved that during the testimony of his accuser, MV, the State identify which testimony

goes with which count. McDaniel stated that this was necessary so he would be able to make

appropriate directed-verdict motions if there was any deficiency in MV’s testimony and for

the jury to determine guilt or innocence on a particular count. The trial court ruled that the

State was not required to do that and denied the motion. McDaniel renewed his motion at

the outset of trial, asking again that during its direct examination of MV, the State be

required to identify on which count it was eliciting testimony. The State responded that this

would invade the province of the jury and that it was the jury’s duty to listen to the testimony

and determine whether there had been sufficient evidence to satisfy the elements of three

counts of rape, four counts of second-degree sexual assault, and one count of sexual

indecency with a child. The trial court again denied McDaniel’s motion over McDaniel’s

objection that “we are entitled constitutionally, and as a matter of procedure, to know which

testimony goes with which count.” McDaniel later renewed his motion after MV testified

on direct examination, after the State rested its case, and each time the trial court again

denied the motion.

3 Also prior to trial, McDaniel filed a request for notice of the State’s expert witnesses,

the curriculum vitae of each expert, any reports or statements made by an expert witness,

and the underlying facts or data forming the basis for their opinions. The State disclosed

Kristi Kirkwood, a forensic interviewer who had interviewed MV about her allegations of

sexual abuse. The State provided McDaniel with Kirkwood’s curriculum vitae and informed

him that although Kirkwood would not be testifying regarding her interview of MV, she

would be called as an expert in the areas of forensic interviewing and the behaviors of child

victims of sexual abuse. Kirkwood’s curriculum vitae showed that she obtained a bachelor

of arts in sociology in 2010; that she has extensive forensic-interview training; that she was a

senior investigator for the Arkansas State Police Crimes Against Children Division from

October 2011 through July 2019, during which time she conducted approximately one

thousand forensic interviews using ChildFirst forensic interviewing protocol; and that she

has been a forensic interviewer for the Texarkana Children’s Advocacy Center from July

2019 through the present.

McDaniel subsequently filed a “Motion to Prohibit Presentation of Supposed Expert

Testimony.” In that motion, McDaniel alleged that the State’s response was inadequate

because it failed to include statements of its expert and also argued that Kirkwood’s proposed

testimony should be prohibited because it would be improper profile evidence as well as

improper bolstering of his accuser. The State filed a response stating that there were no

reports or statements by Kirkwood in connection with the case and that Kirkwood’s

testimony would be based on her years of education, training, and experience. The State

4 alleged further that because it intended to offer only general expert testimony from Kirkwood

about forensic interviews and the five stages of disclosure—and not any specific testimony

about MV or an opinion as to MV’s truthfulness—this testimony was not improper profile

or bolstering evidence under Harper v. State, 2019 Ark. App. 163, 573 S.W.3d. 546.

McDaniel then filed a motion for supplemental discovery, arguing that because Kirkwood

would be testifying from her own experiences, the State should be required to provide the

records from Kirkwood’s case files so McDaniel could cross-examine her on the basis of her

opinions.

The trial court held a pretrial hearing on these issues and ordered to State to provide

to McDaniel training materials and protocols on the “semi-structured narrative process and

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2025 Ark. App. 129, 708 S.W.3d 386, Counsel Stack Legal Research, https://law.counselstack.com/opinion/daryl-brent-mcdaniel-v-state-of-arkansas-arkctapp-2025.