Ex Parte State of Alabama. (in Re R.c.w. v. State of Alabama)

Summary

The court held that the trial court properly admitted evidence of the defendant’s prior sexual misconduct with his daughters to show motive, but gave an erroneous instruction allowing the jury to consider that evidence for opportunity, intent, and plan, which were not disputed issues. Unlike an instruction that provides virtually no meaningful limitation, the instruction here still identified motive as the proper purpose and barred character reasoning; therefore, the error was subject to harmless-error review and was harmless. Justice Shaw concurred in the result on the ground that the instruction did not materially prejudice the defendant, while Justice Murdock, dissenting, would have affirmed because the confusing instruction was potentially prejudicial.