Missouri Court of Appeals, Western District / Dec 21, 2021
State of Missouri vs. Ronald L. Davie
Ronald L. Davie appealed his convictions for first-degree sodomy and incest, arguing the trial court erred by excluding evidence of the victim's prior sexual encounters and bias against homosexual behavior. The appellate court affirmed the convictions, holding that the rape shield statute did not permit evidence of prior sexual conduct to prove 'capacity to consent,' and evidence of bias was irrelevant to that issue. The court also remanded the case for a nunc pro tunc order to correct a clerical error in the written judgment regarding consecutive sentences.