State v. Williams

Travis Williams (defendant) pled guilty in 1996 to a sexual offense against a child. After his release, he married a woman with a young daughter and molested the daughter. The State charged Williams with statutory sodomy and sought a predatory-sexual-offender sentence based on the earlier conviction. A Missouri constitutional amendment lets courts admit prior-crimes evidence in child sex-crime prosecutions to show propensity or corroborate the victim. The trial court admitted the prior conviction on that basis. Williams appealed, arguing that using propensity evidence this way violates due process.