Owen Watson v. State of Arkansas

── Owen Watson v. State of Arkansas ── Court: Supreme Court of Arkansas Date: May 07, 2026 Category: General Cite as 2026 Ark. 97 SUPREME COURT OF ARKANSAS No. CR-25-768 Opinion Delivered: May 7, 2026 OWEN WATSON APPELLANT APPEAL FROM THE CRITTENDEN COUNTY CIRCUIT COURT [NO. 18CR-22-338] V. HONORABLE RANDY PHILHOURS, JUDGE STATE OF ARKANSAS APPELLEE AFFIRMED AS MODIFIED. NICHOLAS J. BRONNI, Associate Justice Owen Watson began raping Minor Victim when she was just ten years old, and four months after she turned fourteen, MV gave birth to Watson’s biological daughter. A jury convicted Watson of child rape, and the circuit court sentenced him to life in prison. He appeals his conviction and sentence, arguing evidentiary issues, judicial bias, and other supposed errors. We reject Watson’s claims and affirm both his conviction and his sentence. Factual and Procedural Background When MV was ten years old, Watson, her mother’s boyfriend, moved into their home. Watson then began raping MV. The abuse continued for years until MV became pregnant—at age thirteen—and her family contacted police. Following an investigation, the State charged Watson with rape. Watson’s trial was short. MV testified that Watson had begun raping her when she was just ten years old, and she described how she had learned she was pregnant. A police officer, Chelsey Stafford, testified about the investigation and, particularly relevant here, how she had collected and stored DNA samples from Watson. A forensic DNA technician, Christopher Glaze, testified that DNA testing confirmed that Watson is the biological father of MV’s child. And Watson did not contest paternity; his counsel repeatedly acknowledged that Watson is the biological father of MV’s child. The jury convicted Watson of rape, and the circuit court sentenced him to life in prison. Watson appeals. Discussion Watson raises five claims on appeal. Broadly speaking, he claims that the circuit court improperly: (1) heard hearsay testimony; (2) admitted DNA evidence without sufficient foundation; (3) denied his motion for a mistrial on the basis of a prospective juror’s statement that she had worked with defense counsel at the public defender’s office; (4) denied his recusal motion; and (5) concluded that he was a habitual offender. None of those claims have any merit, and we affirm Watson’s conviction and sentence. 1. Start with the hearsay claim. Watson argues that the circuit court erred when it permitted Officer Stafford to testify that MV had told her that “Watson had been raping her since she was ten years old.” Watson objected and argued that statement was inadmissible hearsay. The circuit court overruled the objection, explaining the statement was not being used to prove rape but to explain how Officer Stafford got involved with the case and how she conducted her investigation. That was not error. On the contrary, consistent with the circuit court’s conclusion here, we have previously held that “testimony introduced to explain an officer’s actions in pursing and apprehending a suspect is not hearsay.” Dixon v. State, 2011 Ark. 450, at 14–15, 385 S.W.3d 164, 174. So we reject Watson’s argument. 2  2. Second is Watson’s argument that the circuit court erroneously admitted DNA evidence. Watson claims that DNA evidence should never have been admitted because “[t]here was no proof as to the chain of custody of the DNA exhibits whatsoever.” But that is not the case. Officer Stafford testified about collecting DNA samples from Watson and MV’s chi