Missouri Court of Appeals, Western District / Dec 8, 2020
State of Missouri vs. Arthur Norman
Arthur Norman appealed his convictions for first-degree rape and armed criminal action following a bench trial, arguing the trial court erred by admitting certain testimony from a SANE nurse. The appellate court agreed that the nurse's testimony recounting the victim's statements about the attack was inadmissible hearsay, as it exceeded the scope of impeachment and was a post-consistent statement. However, the court affirmed the judgment, applying the presumption that in a bench trial, the court did not rely on inadmissible evidence, and finding overwhelming other evidence of Norman's guilt.