Fells v. State

207 S.W.3d 498, 362 Ark. 77
CourtSupreme Court of Arkansas
DecidedApril 21, 2005
DocketCR 04-1237
StatusPublished
Cited by28 cases

This text of 207 S.W.3d 498 (Fells v. State) is published on Counsel Stack Legal Research, covering Supreme Court of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fells v. State, 207 S.W.3d 498, 362 Ark. 77 (Ark. 2005).

Opinions

Betty C. Dickey, Justice.

Korey Fells was convicted in the Pulaski County Circuit Court of the rape of S.H. and sentenced to a term of eighteen years. On appeal, Fells argues that the trial court erred in (1) refusing to allow him to cross-examine a witness using a police case summary, (2) refusing to allow the defense to present evidence that the rape victim had tested positive for the human immunodeficiency virus (HIV), and (3) admitting the testimony of the alleged victim of an earlier rape by Fells. We affirm.

Facts

S.H., the rape victim, testified that on February 3, 2002, Super Bowl Sunday, she was standing in the entrance to the Shorter Gardens housing project when Fells drove up and beckoned to her. When S.H. approached his car, he rolled down his window and asked if he knew her. The two then talked for about twenty to thirty minutes. S.H. mentioned that she was hungry, and he offered to drive her to a gas station so that she could get something to eat. Fells complimented S.H. on her physical appearance, and he portrayed himself as a trustworthy friend in whom she could confide. On the way to the gas station, he asked S.H. if she wanted to drive with him so that they could watch the Super Bowl on his car’s television and S.H. could finish talking about her problems. S.H. agreed. He drove several miles and parked in an area with which S.H. was unfamiliar. While they drove, S.H. told Fells that she was pregnant and had suffered complications from her pregnancy earlier that day. She also told him that there were warrants out for her arrest and that she had few friends and nowhere to go. Fells parked his car, and the two sat in the backseat so that they could watch the Super Bowl. He then began to grope S.H. When she protested, he threatened to leave her to find her own way home. S.H. testified that she then feared for her life and the life of her unborn child, and she submitted. Shortly thereafter, police officers approached the vehicle. Fells told the police that everything was fine, but S.H. said that she had been raped. He then told the officers S.H.’s name and that she had warrants out for her arrest. S.H. left with the police, and Fells was eventually charged with rape.

Just before trial, the State moved in limine to prevent Fells from questioning S.H. regarding her HIV-positive status. The court granted the State’s motion. Fells and S.H. testified at trial, as did R.B., the alleged victim of an earlier rape by Fells. Fells moved to exclude R.B.’s testimony on the grounds that its only purpose was to portray him as a criminal character, but the court determined that the testimony was admissible under Rule 404(b) as evidence of modus operandi. After R.B. testified that she had felt threatened by Fells, his attorney attempted to cross-examine her by reading a police case summary in which a detective noted that R. B. had told him that Fells had not threatened her in any way. The jury found Fells guilty of rape, and the trial court entered judgment on September 17, 2003.

The court of appeals reversed Fells’s conviction, holding that Fells should have been able to present evidence that S.H. was HIV-positive and that R.B.’s testimony should have been excluded. We now affirm the trial court and reverse the court of appeals.

Standard of Review

Upon petition to review a decision of the court of appeals, this court reviews the case as if it had originally been filed in this court. Hence, this court’s review centers on the trial court’s decision, not on the decision of the court of appeals. Lewellyn v. Lewellyn, 351 Ark. 346, 93 S.W.3d 681 (2002).

Fells disputes three of the trial court’s evidentiary rulings. The admission or rejection of testimony is a matter within the trial court’s sound discretion and will not be reversed on appeal absent a manifest abuse of that discretion and a showing of prejudice to the defendant. Ellison v. State, 354 Ark. 340, 123 S. W.3d 874 (2003).

Cross-Examination ofR.B.

At trial, the State called as a witness R.B., the alleged victim of an earlier rape by Fells, who testified that Fells had threatened her during the incident. Fells’s attorney attempted to cross-examine R.B. as follows:

Q. Did you at any time tell Detective Massiet, “At no time did Mr. Fells threaten her safety,” [her] meaning you, “in any way to have sex?”
A. Say that again, I’m sorry.
Q. Did you tell Detective Massiet — and I’m going to read this verbatim.
A. Uh-huh.
Q. [R.B.] said at no time did Mr. Fells threaten her safety in any way to have sex.

The State immediately objected that this line of questioning was based on inadmissible hearsay; Fells was attempting to use Detective Massiet’s out-of-court statement to prove that R.B. had not been threatened by Fells. The trial court sustained the State’s objection. Fells now argues that Detective Massiet’s case notes should have been admitted under Ark. R. Evid. 801(d)(1) (2004), because he was using them to impeach R.B.’s credibility.

Rule 801(d)(1) excludes from the definition of hearsay a witness’s prior inconsistent statement if the statement, when offered in a criminal proceeding, “was given under oath and subject to the penalty of perjury.” The proffered statement does not fall under the hearsay exception of Rule 801(d). It is a statement made by a police detective, not R.B., nor is it a statement that was given under oath and subject to the penalty of perjury. The trial court did not err in excluding this piece of testimony.

S.H.’s HIV Status

Fells next argues that the trial court erred in refusing to allow him to present evidence that the rape victim, S.H., was HIV-positive. He contends that this evidence was admissible because it showed that S.H. had a motive to lie about being raped. According to Fells, because it is a crime for a person to knowingly expose another to HIV, S.H. “knew that if she did not say she was raped, it would be consensual sex and she’d be charged with a crime.”

Under Arkansas’s rape-shield statute, Ark. Code Ann. § 16-42-101 (Repl. 1999), evidence of a victim’s prior sexual conduct may be introduced at trial only after the proponent of the evidence has first filed a written motion explaining its relevance, and after the court has held a hearing and determined that the evidence is more probative than prejudicial. Although Fells admits that he did not comply with the required procedures, he argues that the information was not subject to the rape-shield law because it did not address any prior sexual activity, merely the fact that S.H. was HIV-positive.

The issue of whether a victim’s HIV status falls under the purview of the rape-shield statute is one of first impression. We hold that the HIV status of a rape victim is protected under Arkansas’s rape-shield statute. The statute prohibits the use of past sexual behavior to embarrass and degrade victims; its purpose is to shield rape victims from public humiliation. Short v. State, 349 Ark. 492; 79 S.W.3d 313 (2002).

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Cite This Page — Counsel Stack

Bluebook (online)
207 S.W.3d 498, 362 Ark. 77, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fells-v-state-ark-2005.