Supreme Court of Arkansas

Edward Darnell Rogers v. State of Arkansas

October 25, 2018558 S.W.3d 833

Summary

The court granted rehearing, substituted its prior opinion, and reversed Rogers's three rape convictions because the circuit court improperly excluded evidence of L.W.'s theft-of-property conviction for impeachment. Under Arkansas Rule of Evidence 609(a), theft of property is a crime involving dishonesty and is automatically admissible to attack credibility, and the exclusion was not harmless because the prosecution's case depended on the victims' credibility and their allegations were intertwined. The court also held that Rogers's renewed sufficiency arguments based on delayed reporting, lack of physical evidence, and credibility were not preserved.