Kyle Wayne Fairless v. State of Arkansas

2025 Ark. App. 460
CourtCourt of Appeals of Arkansas
DecidedOctober 1, 2025
StatusPublished

This text of 2025 Ark. App. 460 (Kyle Wayne Fairless 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
Kyle Wayne Fairless v. State of Arkansas, 2025 Ark. App. 460 (Ark. Ct. App. 2025).

Opinion

Cite as 2025 Ark. App. 460 ARKANSAS COURT OF APPEALS DIVISION II No. CR-24-767

KYLE WAYNE FAIRLESS Opinion Delivered October 1, 2025

APPELLANT APPEAL FROM THE POLK COUNTY CIRCUIT COURT V. [NO. 57CR-22-172]

STATE OF ARKANSAS HONORABLE MARCIA R. APPELLEE HEARNSBERGER, JUDGE

AFFIRMED

CINDY GRACE THYER, Judge

A Polk County jury convicted appellant Kyle Fairless of raping his stepdaughter, MV,1

and sentenced him to ten years’ incarceration in the Arkansas Division of Correction. He

now appeals that conviction, alleging that the circuit court erred in restricting his ability to

impeach MV’s testimony with evidence of an attempted settlement and in allowing MV’s

mother to testify regarding her emotional reaction to MV’s disclosure. We affirm.

1 The victim in this case was a minor when the alleged sexual abuse occurred but had reached the age of majority by the time charges were filed. However, in the spirit of protecting the minor victim’s anonymity as set forth in Rule 6-3(b) of the Arkansas Rules of the Arkansas Supreme Court and Court of Appeals, we will identify the victim as MV in this opinion. I. Factual and Procedural History

When MV was approximately seventeen years old, she disclosed to a friend that her

stepfather, Kyle Fairless, had been sexually abusing her. The secret remained between MV

and her friend until September 2017 when MV again disclosed the abuse to some friends

and ultimately to her mother.

MV claimed that shortly after her mother and Fairless were married, he began sexually

abusing her. According to MV, the abuse began when she was approximately eight or nine

years old. She claimed that over the years, Fairless digitally penetrated her; he penetrated her

both orally and vaginally; he would molest her while she was showering; and he ultimately

had vaginal intercourse with her.2

After MV disclosed the abuse to her mother, her mother immediately reported the

abuse to law enforcement. Because some of the alleged abuse occurred in Oklahoma, law

enforcement in both Oklahoma and Arkansas investigated the allegations. 3 Oklahoma

authorities declined prosecution.

After initially declining to file charges, in November 2022, the State of Arkansas filed

a criminal information against Fairless alleging one count of rape. However, at some point

during the five-year interim between the disclosure and the filing of charges, Fairless was

2 Because sufficiency of the evidence is not at issue, the precise details of the alleged abuse are not repeated here. 3 We note there is some indication in the record that Texas authorities also conducted an investigation, but the extent of that investigation is unclear.

2 placed on the Child Maltreatment Registry, and he appealed that placement. Then, on July

24, 2019, while that administrative appeal was ongoing and before criminal charges were

brought, MV allegedly texted either the Arkansas State Police investigator or the DHS

attorney handling the child-maltreatment action and proposed a settlement. 4 The text

message stated the following:

Hello, this is [MV] I have a case open against Kyle Fairless for rape and molestation over a period of 10 years. I was wondering if there would be a way for me to be able to reach a settlement and drop the case- and if need be sit down alissa, you, me, Kyle and his lawyer’s, and come to some agreement. I would like to propose a payout of at least 15,000 for the damages to my mental health and trauma he has caused me- but I am aiming higher in case they want to negotiate lower. I have been kicked out of my friends house once again, and my fiancé and I had just gotten jobs and was getting our life back to being stable again. I have had to go to a psychiatric hospital and numerous other things have happened to due [sic] the trauma he has caused me. I even attempted taking my life twice here recently which had caused me to be admitted to Brentwood. The only reason I’m finally throwing my hands up and saying fuck it I need this compensation is because mine and my family’s stability is more important to me than anything else. The compensation would be able to get me and my family multiple months rent, so we could save up with our current jobs, and other necessities needed at this time of homelessness for us. Let me know your opinion as soon as possible please. It’s dire.

There is no evidence a settlement was ever reached or that the settlement offer was

ever communicated to Fairless or his attorneys.

The criminal information against Fairless was amended multiple times between

March 2022 and April 2024 when he was ultimately charged with three counts of rape. The

4 At certain times below, the parties claimed the text message was sent to the Arkansas State Police investigator. At other times they claimed the message was texted to the DHS attorney handling the child-maltreatment action. In their appellate briefs, the parties state that the text message was between MV and the state police investigator. No clarifying evidence from either the investigator or the DHS attorney was presented.

3 first count alleged that Fairless engaged in deviate sexual activity with MV between August

1, 2011, and March 19, 2014, while MV was under the age of fourteen. The second and

third counts alleged that between August 1, 2013, and May 31, 2014, and between March

20, 2014, and November 30, 2016, Fairless, while MV’s guardian, engaged in sexual

intercourse or deviate sexual activity with her.

Before trial, the parties filed several motions in limine. Fairless’s motion requested

that all evidence related to the child-maltreatment proceedings be prohibited as well as any

administrative findings from Arkansas, Oklahoma, or Texas. The State then filed a motion

seeking, in part, to prohibit any evidence that Oklahoma or Arkansas had declined to

prosecute Fairless for the same or similar conduct. The court granted both motions.

The State also filed a motion in limine seeking to prohibit Fairless from introducing

evidence that MV had inquired into her options for a civil settlement, claiming that such

evidence would be prejudicial and because there was no evidence that MV had offered to

drop the current charges or recant her allegations in exchange for a cash settlement. In a

hearing on this motion, the State explained that MV thought the DHS attorney who was

involved in the child-maltreatment appeal was her attorney, and MV asked the attorney, in

a text message, whether they could reach a settlement. The prosecuting attorney indicated

she was not aware of MV having filed a civil suit and argued that allowing the introduction

of the text message would be misleading to the jury because they “might infer she intended

to have the defendant pay her not to file charges . . . or something of that nature.” She argued

that to admit this evidence would be irrelevant and extremely prejudicial to the State.

4 Relying on Wilson v. State, 289 Ark. 141, 712 S.W.2d 654 (1986), defense counsel

responded that to exclude this evidence would be reversible error. He pointed out that MV

had reached out to “a state attorney who did not represent her,” proposing to settle this case

for $15,000. The court responded that “this case cannot be settled,” to which defense

counsel replied, “No. But proposing to settle out with him for a cash value; proposing that

he pay her 15,000 bucks and that she be done with all of this stuff.” The State countered

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2025 Ark. App. 460, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kyle-wayne-fairless-v-state-of-arkansas-arkctapp-2025.