State v. Mitchell

NEUMAN, Justice

(dissenting).

The decision whether to admit evidence of prior bad acts is necessarily a discretionary one dependant on the facts of each case. Given the facts before us, I cannot agree that admitting Susanna’s and Karen’s testimony of similar sexual abuse by Mitchell constituted an abuse of the trial court’s discretion. I therefore respectfully dissent.

The majority takes great pains to point out the role propensity plays in using Susanna’s and Karen’s testimony to bolster Amy’s credibility. However, we have consistently recognized that, as long as the disputed evidence speaks to a legitimate factual issue, the fact that it may also speak to propensity is immaterial; the evidence is admissible for that other purpose. See Castaneda, 621 N.W.2d at 440; Plaster, 424 N.W.2d at 229. So long as we recognize this distinction, we do not hasten the demise of the exclusionary principle *301embodied in rule 404(b) but allow the fact finder to evaluate all of the circumstances surrounding the abuse.

It is no coincidence that questions concerning prior bad acts often arise in cases of sexual abuse. These crimes, especially when committed against children, take place in secret, far from the view of witnesses who could corroborate the victims’ stories. Congress bore this fact in mind when it adopted Federal Rule of Evidence 414, making evidence of prior sexual assaults of children admissible for any purpose for which it is relevant in the prosecution of other sexual assault cases. Fed. R.Evid. 414(a). This rule recognizes the special nature of crimes of sexual abuse against children, and the fact that evidence of prior, similar actions is highly probative and relevant.

The relevance in this case is obvious. The fact that Susanna and Karen both testified that Mitchell touched them in places and ways similar to Amy makes it more likely that Amy was testifying truthfully about her own abuse at the hands of her mother’s boyfriend. This became an issue when Mitchell, on his cross-examination of Amy, attempted to establish a motive for Amy to fabricate her story. Mitchell introduced this issue and should not, in fairness, be allowed to escape the consequences. The State was well within its right to present evidence to counter his claim, and the district court correctly found the tendered proof was relevant. For these reasons, I would join those states that have affirmed the use of other bad acts evidence to counter a defendant’s allegation that a victim has fabricated claims of abuse. See Hardeman v. State, 247 Ga.App. 503, 544 S.E.2d 481, 485 (2001); Rigler v. State, 941 P.2d 734, 738 (Wyo.1997); Daniel v. State, 923 P.2d 728, 735 (Wyo.1996).

I also disagree with the majority’s conclusion that the evidence’s probative value is substantially outweighed by the danger of unfair prejudice to Mitchell. In order to properly engage in the balancing required by Iowa Rule of Evidence 403, I must start from the same premise as the court of appeals: the purpose of all evidence is to sway the fact finder. Moreover, in cases of child sexual abuse, most of the evidence, by its nature, will be shocking and at least somewhat prejudicial. Exclusion is required only when evidence is unfairly prejudicial and substantially outweighs its probative value. That is not the case here.

The State’s need for the evidence, the strength of Susanna’s and Karen’s testimony and the proofs strong connection to Amy’s credibility make the probative value of the girls’ testimony high. Granted the similar nature of the abuse makes the evidence more prejudicial. Its impact, however, was tempered by the court’s two limiting instructions, given both immediately prior to the testimony and as part of the jury instructions. The jury was well aware for what purpose it could consider the sisters’ testimony, and we must presume the jury followed the court’s instructions. Plaster, 424 N.W.2d at 432.

Given all of these factors, I cannot say that Mitchell met his burden of showing that any prejudice substantially outweighed the testimony’s probative value. The majority’s holding to the contrary merely rewards Mitchell for attacking his victim and once again leaving her defenseless. I would affirm the decision of the court of appeals and the judgment of the district court.

TERNUS, J., joins this dissent.