Andrew M. Holland, Appellant v. State of Arkansas, Appellee

Summary

The court affirmed Holland’s convictions for first- and second-degree sexual assault. It held that the prior-acts evidence was admissible under the pedophile exception and was not excluded by remoteness, unreliability, or unfair prejudice; that the proposed victim-motive evidence was barred by the rape-shield statute; and that denial of access to privileged psychological records did not violate Holland’s constitutional rights because the circuit court conducted in-camera reviews and the records had little evidentiary value. Justices Hart and Wynne dissented, concluding that the Rivendell records contained material impeachment evidence and that the privilege should yield to Holland’s constitutional rights.