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Fells v. State
Supreme Court of Arkansas (2005) | 207 S.W.3d 498; 362 Ark. 77
TL;DR: A defendant's rape conviction was affirmed after the court held that the victim's HIV status was protected by the rape-shield statute and that testimony about a prior alleged rape was admissible under Rule 404(b) to prove the defendant's intent and plan.
Legal Significance: This case establishes that a rape victim's HIV status is considered evidence of "prior sexual conduct" under Arkansas's rape-shield statute, requiring specific procedures for admission. It also clarifies the application of Rule 404(b) for prior acts showing intent in sexual assault cases.