R. C. W. v. AlabamaAnnotate this Case
R.C.W. was convicted of first-degree rape, first-degree sexual abuse, and two counts of first-degree sodomy. The trial court sentenced R.C.W., pursuant to the Habitual Felony Offender Act, to life imprisonment on the incest and first-degree-sexual-abuse convictions and to life imprisonment without the possibility of parole on the first-degree rape and both first-degree-sodomy convictions. The Court of Criminal Appeals reversed R.C.W.'s convictions in a 3 to 2 decision. The Supreme Court granted the State's petition for a writ of certiorari to determine, as a matter of first impression, whether an erroneous limiting instruction, as to otherwise properly admitted Rule 404(b) collateral-acts evidence, was subject to a harmless-error analysis. In this matter, the Court agreed with the Court of Criminal Appeals that the evidence relating to R.C.W.'s prior sexual misconduct with his daughters was admissible to show motive. Furthermore, the Court agreed that the trial court's limiting instruction was erroneous because it permitted the jury to consider the collateral-acts evidence for issues not in dispute. The Court applied a harmless-error analysis and concluded that any error arising from the trial court's limiting instruction was harmless and was not prejudicial to R.C.W. Accordingly, the judgment of the Court of Criminal Appeals was reversed, and the case remanded for further proceedings.