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Arkansas Supreme Court Upholds Teen's Sexual Assault Conviction

The Arkansas Supreme Court affirmed a circuit court's delinquency finding against a teenage defendant who sexually assaulted his 5-year-old half-niece on Thanksgiving Day 2022. The high court rejected the minor's arguments challenging both the sufficiency of evidence and the admission of a forensic interview with the victim.

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Seal of the Arkansas Supreme Court

Case Information

Case No.:
CR-24-282

Key Takeaways

  • Arkansas Supreme Court affirmed delinquency finding for second-degree sexual assault
  • Teenage defendant was the 5-year-old victim's half-uncle, attack occurred on Thanksgiving 2022
  • Court rejected challenges to evidence sufficiency and admission of victim's forensic interview

The Arkansas Supreme Court affirmed a Saline County Circuit Court's delinquency finding against a teenage defendant who committed second-degree sexual assault against his 5-year-old half-niece on Thanksgiving Day 2022. In *Minor Child v. State of Arkansas* (Ark. 2025), Associate Justice Nicholas J. Bronni wrote the opinion rejecting the minor's appeal and upholding the lower court's adjudication.

The case arose from disturbing circumstances involving a teenage defendant, identified only as MC, and his then-5-year-old victim, who was his half-niece. On Thanksgiving morning 2022, MC was staying with the victim's family when the assault occurred.

According to court records, the victim woke up early that morning and went to her parents' bedroom before proceeding to the living room. There she discovered MC on the couch and, believing he was asleep, joined him. However, MC was awake and proceeded to digitally penetrate the victim's rectum. When the victim felt "sad and mad" and "scooted up" to alleviate her discomfort, MC digitally penetrated her "one more time" before stopping when the victim's mother entered the room.

Later that day, the victim's father took MC home while the family left to celebrate Thanksgiving with extended family. Upon returning home that evening, the victim disclosed to her father that she did not like how MC had touched her earlier. Immediately recognizing something was wrong, the father called the victim's mother into the room, and the victim told them what had happened.

The case proceeded through the Saline County Circuit Court under the Honorable Brent Houston, who found the minor delinquent for committing second-degree sexual assault. MC subsequently appealed the delinquency finding to the Arkansas Supreme Court, raising two primary arguments.

First, MC argued that there was insufficient evidence to support the circuit court's delinquency finding. The teenager challenged whether the evidence presented at trial was adequate to establish his guilt beyond a reasonable doubt for the charged offense.

Second, MC contended that the circuit court erred in admitting a recorded interview between the victim and a forensic nurse. This evidentiary challenge focused on whether the forensic interview should have been excluded from the proceedings, potentially affecting the outcome of the case.

The Arkansas Supreme Court rejected both arguments in its December 11, 2025 opinion. Justice Bronni, writing for the court, found that the evidence was sufficient to support the delinquency finding and that the circuit court properly admitted the forensic interview.

The court's decision to affirm the lower court's ruling means that the teenage defendant's delinquency finding for second-degree sexual assault remains in place. The opinion demonstrates the court's careful consideration of both the evidentiary standards required in juvenile delinquency proceedings and the proper admission of forensic interviews involving child victims.

This case highlights several important legal principles in Arkansas juvenile law. The court's analysis of evidence sufficiency in cases involving child victims reflects the state's approach to protecting young witnesses while ensuring due process rights for juvenile defendants. The admission of forensic interviews represents a critical tool in prosecuting cases involving child victims, who may face challenges testifying in formal court proceedings.

The Arkansas Supreme Court's affirmation also underscores the state's commitment to holding juvenile offenders accountable for serious crimes, even when the defendants are minors themselves. The case involved particularly egregious conduct against a very young victim within a family setting, circumstances that likely influenced the court's analysis.

The opinion, cited as *2025 Ark. 210*, establishes precedent for similar cases involving juvenile defendants charged with sexual assault offenses against child victims. The court's rejection of the evidentiary challenges may provide guidance for future cases involving forensic interviews and evidence sufficiency standards in juvenile proceedings.

The case originated in Saline County Circuit Court under case number 63JV-23-24 before reaching the Arkansas Supreme Court as case number CR-24-282. The procedural history demonstrates the thorough review process available to juvenile defendants in Arkansas, including the right to appeal delinquency findings to the state's highest court.

While the court noted that the facts were "disturbing," Justice Bronni emphasized that the opinion would recount only those facts necessary to resolve the legal issues presented. This approach reflects the court's sensitivity to the serious nature of the case while maintaining focus on the legal questions at hand.

The affirmation of the delinquency finding ensures that the juvenile justice system's determination stands, providing accountability for the serious offense while protecting the young victim's interests through the proper legal channels.

Topics

sexual assaultjuvenile justicecriminal appealevidence admissibilityforensic examination

Original Source: courtlistener

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