Vance v. State
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Appellant appealed a conviction and sentence to life imprisonment without parole. The appellant made several arguments, including the arguments that the circuit court erred (1) by failing to suppress evidence derived from his DNA sample and statements he made to police officers; (2) by allowing the introduction of evidence of other crimes; and (3) by excluding expert evidence vital to his defense. The Supreme Court found no error and affirmed. The Court determined that (1) appellant voluntarily accompanied police officers to the station and made a valid waiver of his rights, and therefore the circuit court correctly denied the motion to suppress evidence based on an illegal seizure; (2) pursuant to Ark. R. Evid. 403, introducing evidence of previous crimes was not outweighed by the danger of unfair prejudice; and (3) pursuant to Ark. R. Evid. 702, the trial court did not abuse its discretion by excluding expert testimony on the relationship between diminished IQ and false confessions when the defendant had an opportunity to cross-examine the officers about the confession and the proffered testimony would have invaded the jury’s function as trier of fact.
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