Michael Moore v. State of Arkansas

2025 Ark. App. 176
CourtCourt of Appeals of Arkansas
DecidedMarch 19, 2025
StatusPublished

This text of 2025 Ark. App. 176 (Michael Moore 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
Michael Moore v. State of Arkansas, 2025 Ark. App. 176 (Ark. Ct. App. 2025).

Opinion

Cite as 2025 Ark. App. 176 ARKANSAS COURT OF APPEALS DIVISION IV No. CR-24-214

MICHAEL MOORE Opinion Delivered March 19, 2025

APPELLANT APPEAL FROM THE POLK COUNTY CIRCUIT COURT V. [NO. 57CR-22-173]

STATE OF ARKANSAS HONORABLE ANDY RINER, JUDGE APPELLEE AFFIRMED

CASEY R. TUCKER, Judge

Following a two-day jury trial beginning on October 16, 2023, the Pope County

Circuit Court convicted Michael Moore of rape and sentenced him to forty years in the

Arkansas Division of Correction. He appeals his conviction, asserting that the circuit court

erred in allowing two witnesses to testify pursuant to the pedophile exception to Arkansas

Rule of Evidence 404(b). Moore also argues that the circuit court erred in allowing one of

the witnesses to testify when the State had not properly disclosed her contact information

and expected testimony as required by Arkansas Rule of Criminal Procedure 17.1. We

affirm.

According to the testimony at trial, Minor Victim (MV) and Moore are first cousins.

When MV was young, her family spent a lot of time visiting Moore’s family, often late into

the night. On one of these visits, when MV was only seven years old and Moore was eighteen, MV went to sleep in Moore’s bedroom. Moore entered the bedroom, ripped MV’s pajamas

from her body, and raped her. He told MV not to tell anyone.

A few years later, at MV’s birthday party the year she turned ten, MV was changing

clothes alone in her bedroom when Moore entered the room. As he approached MV, he

said, “It’s just like last time.” MV responded, “no.” At that point another family member

entered the room and asked Moore what he was doing; he stated he was looking for the

bathroom.

MV kept these events to herself until she was fourteen years old, when during an

argument with her parents, MV blurted out what Moore had done to her when she was

seven. MV’s parents sought counseling for MV. The counselor reported Moore’s actions to

law enforcement, and MV and her family cooperated with the investigation.

Moore has two other female cousins who testified at trial that he had sexually

assaulted them. One of the cousins, Jaden, was adopted by her grandparents, who were also

Moore’s grandparents. At one time, he lived in a camper in their yard. Jaden testified that

when she was five years old, Moore1 lay down in her bed with her and put his hand inside

her pants, touching her skin in the genital area. This happened several more times while

Jaden was five years old. According to Jaden, Moore molested her for the last time when she

was eleven years old by again putting his hand inside her pants and touching her vagina. This

occurred in his camper while other cousins were present.

1 Moore would have been approximately twelve years old when this incident occurred.

2 Moore’s other cousin, Jessica, testified she also was sexually assaulted by Moore in his

camper the same night as Jaden. Jessica testified that Moore served her alcohol to the point

that she passed out and woke up while Moore was raping her. She tried to tell him no and

to resist but was unsuccessful. When she woke up the next morning, she was naked and in

pain. Jessica was sixteen, and Moore was eighteen years old.

I. Pedophile Exception

Moore first argues on appeal that the circuit court erred in allowing Jaden’s and

Jessica’s testimony because his actions with them were too dissimilar to his alleged assault of

MV to be admissible under the pedophile exception to Ark. R. Evid. 404(b). We disagree.

In making evidentiary decisions, the circuit court has broad discretion, and its

decision will not be reversed absent an abuse of that discretion. Duvall v. State, 2018 Ark.

App. 155, 544 S.W.3d 106. In order to find an abuse of discretion, this court must find that

the circuit court acted improvidently, thoughtlessly, or without due consideration. Id.;

Washington v. State, 2024 Ark. App. 134, 686 S.W.3d 61. This court further explained in

Washington that

even if a circuit court errs in admitting evidence, this court may affirm a conviction and deem the error harmless if the evidence of guilt is overwhelming and the error is slight. Prejudice is not presumed on appeal; and an assessment of prejudice must take into account that the uncorroborated testimony of a minor victim alone is substantial evidence to sustain a conviction for sex offenses.

2024 Ark. App. 134, at 9, 686 S.W.3d at 67 (citations omitted).

The general rule regarding the inadmissibility of other bad acts is Arkansas Rule of

Evidence 404(b), which provides:

3 Other Crimes, Wrongs, or Acts. Evidence of other crimes, wrongs, or acts is not admissible to prove the character of a person in order to show that he acted in conformity therewith. It may, however, be admissible for other purposes, such as proof of motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident.

This court has recognized a pedophile exception to the general rule that evidence of other

bad acts is not admissible to show that the accused acted in conformity therewith. Duvall,

2018 Ark. App. 155, 544 S.W.3d 106. In Hortenberry v. State, the supreme court explained

the pedophile exception:

The pedophile exception allows the State to introduce evidence of a defendant’s similar acts with the same or other children when it is helpful in showing a proclivity for a specific act with the person or class of persons with whom the defendant has an intimate relationship. E.g., Hendrix v. State, 2011 Ark. 122. The rationale for this exception is that such evidence helps to prove the depraved sexual instinct of the accused. E.g., Flanery v. State, 362 Ark. 311, 208 S.W.3d 187 (2005). There are two requirements for this exception to apply: (1) a sufficient degree of similarity between the evidence to be introduced and the charged sexual conduct, and (2) evidence of an “intimate relationship” between the defendant and the victim of the prior act. See, e.g., Rohrbach v. State, 374 Ark. 271, 287 S.W.3d 590 (2008).

2017 Ark. 261, at 9–10, 526 S.W.3d 840, 846–47.

We first look at the degree of similarity between the evidence the State presented

through Jessica and Jaden and the crime with which Moore was charged. Moore asserts that

the circuit court should not have allowed Jessica to testify because she was sixteen years old

when he allegedly raped her, whereas MV was only seven years old. Moore goes on to argue

that it is significant that when Moore allegedly raped MV, they were alone in his bedroom,

but when he allegedly raped Jessica they were in his camper with other people present. He

also points out the fact that alcohol was involved in the incident with Jessica, and there was

4 no evidence of alcohol consumption in the incident with MV. Moore asserts that although

Jessica was not capable of consent due to intoxication, she was legally of an age to consent.

These asserted differences are of little consequence to the similarity prong of the pedophile-

exception test.

First, as pointed out by the State, for purposes of sex offenses, a minor is a person

under the age of eighteen years. Ark. Code Ann. § 5-14-101(7) (Repl. 2024); see also Craigg

v. State, 2012 Ark.

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Related

Rohrbach v. State
287 S.W.3d 590 (Supreme Court of Arkansas, 2008)
Swift v. State
215 S.W.3d 619 (Supreme Court of Arkansas, 2005)
Parish v. State
163 S.W.3d 843 (Supreme Court of Arkansas, 2004)
Nooner v. State
907 S.W.2d 677 (Supreme Court of Arkansas, 1995)
Flanery v. State
208 S.W.3d 187 (Supreme Court of Arkansas, 2005)
Kelley v. State
2009 Ark. 389 (Supreme Court of Arkansas, 2009)
Hortenberry v. State
2017 Ark. 261 (Supreme Court of Arkansas, 2017)
Craigg v. State
2012 Ark. 387 (Supreme Court of Arkansas, 2012)
Arnold v. State
540 S.W.3d 298 (Court of Appeals of Arkansas, 2018)
Duvall v. State
544 S.W.3d 106 (Court of Appeals of Arkansas, 2018)
George Gitchell v. State of Arkansas
2023 Ark. App. 503 (Court of Appeals of Arkansas, 2023)

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2025 Ark. App. 176, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michael-moore-v-state-of-arkansas-arkctapp-2025.