State v. WilliamsAnnotate this Case
Article I, section 18(c), which voters added to the Missouri Constitution in 2014, does not violate due process.
Defendant was convicted of three counts of first-degree statutory sodomy. On appeal, Defendant challenged the constitutionality of article I, section 18(c), arguing that it violates due process because it allows admission of evidence of prior criminal acts in the prosecution’s case-in-chief to prove a defendant has the propensity to commit the charged crime. The Supreme Court held (1) article I, section 18(c) does not violate federal due process on its face; (2) the circuit court is not required to make an express finding of legal relevance before admitting evidence under article I, section 18(c), provided the record reflects a sound basis for the balancing the amendment requires; and (3) the circuit court did not err in admitting evidence of Defendant’s prior criminal act because the danger of unfair prejudice from that evidence did not substantially outweigh its probative value.