Eric Stevens v. State of Arkansas

── Eric Stevens v. State of Arkansas ── Court: Court of Appeals of Arkansas Date: April 15, 2026 Category: General Cite as 2026 Ark. App. 232 ARKANSAS COURT OF APPEALS DIVISION I No. CR-25-238 ERIC STEVENS Opinion Delivered April 15, 2026 APPELLANT APPEAL FROM THE ASHLEY COUNTY CIRCUIT COURT V. [NO. 02CR-23-198] STATE OF ARKANSAS HONORABLE ROBERT B. GIBSON III, APPELLEE JUDGE AFFIRMED ROBERT J. GLADWIN, Judge An Ashley County jury convicted Eric Stevens of second-degree sexual assault. On appeal, he argues that the circuit court (1) erred in denying his motion for directed verdict and (2) abused its discretion by excluding certain impeachment evidence—specifically, testimony about an alleged previous false statement that the minor victim (MC) had made against him. We affirm. I. Facts and Procedural History On October 10, 2023, at approximately 6:30 a.m., Officer Josh Pollock of the Ashley County Sheriff’s Office responded to a call from then seventeen-year-old MC claiming that she had been raped. According to the probable-cause affidavit, MC told Officer Pollock that she had been asleep in her room the previous night and was awakened by the realization that Stevens, who was her uncle’s forty-five-year-old friend, was lying behind her and had inserted his penis into her vagina. MC stated that this scared her and that when Stevens realized she was awake, he jumped up and ran out of the room. MC explained that she then ran next door to her cousin’s house where her cousin texted an Ashley County patrolman who notified Officer Pollock. The State charged Stevens with one count of rape in violation of Arkansas Code Annotated section 5-14-103 (Supp. 2023). Before trial, the State moved to exclude evidence that MC previously had made false statements against Stevens. Specifically, during his custodial interview, Stevens alleged that MC, when she was investigated for possession of a marijuana gummy at school, told the authorities that he supplied her the drugs. The State argued that the evidence should be excluded under Arkansas Rule of Evidence 403. Specifically, the State claimed that the evidence had minimal probative value, noting that the only evidence of the claim was Stevens’s own testimony and that the investigator on MC’s case had found no record of MC making the allegation. The State further argued that the evidence was unfairly prejudicial because it would reveal that MC was on juvenile probation for a misdemeanor, a fact that would otherwise be inadmissible. Stevens countered that he had the right to cross-examine MC about the incident because it went to her credibility as a witness and her propensity for truthfulness. The circuit court granted the State’s motion and excluded the evidence, finding that its prejudicial effect outweighed its probative value and that the evidence was not proper for impeachment. A jury trial was held on January 16, 2025. MC testified that on the evening of October 10, 2023, she was asleep in her bed when she was suddenly awakened by the feeling of a man 2 lying in the bed behind her, inserting his penis into her vagina. Her underwear and shorts had been pulled down around her knees, and she could feel his penis “inside of” her. MC specifically noted that she was asleep when the man first penetrated her vagina. She testified that she was afraid, unable to move, unable to breathe, unable to do anything but lie there helplessly and pretend to be asleep. She testified that eventually she recovered enough to move, and when the