Background
Randy Lynn Knotts was convicted of eleven felonies arising from the alleged sexual abuse of his stepdaughter when she was between eleven and fourteen years old. The convictions included one count of first-degree sexual assault, six counts of third-degree sexual assault, and four counts of sexual abuse by a parent, guardian, custodian, or person in a position of trust. He received an aggregate indeterminate prison sentence of seventy-one to 210 years.
When Knotts testified and denied the allegations, the prosecutor asked whether he was a violent man. After he answered no, the State confronted him with misdemeanor domestic battery and domestic assault convictions from 1997, 1998, and 2002. The State again invoked that history during closing argument, asserting that Knotts had lied about it. The circuit court ruled that the questioning properly rebutted evidence of Knotts’s character for peacefulness and alternatively concluded that any error was harmless.
The Court’s Holding
The Supreme Court of Appeals held that the convictions were inadmissible under West Virginia Rules of Evidence 404(a)(2)(A) and 609. Knotts did not place his character for peacefulness at issue merely by denying the charged offenses and related allegations. The prosecutor could not manufacture an opportunity for rebuttal by asking whether he was violent and then use his answer to introduce otherwise inadmissible specific acts.
The convictions also could not be used to impeach Knotts’s credibility under Rule 609 because they did not involve perjury or false swearing. Their age created an additional barrier: they were approximately twenty years old, the State provided no reasonable written notice of its intent to use them, and it identified no circumstances showing that their probative value substantially outweighed their prejudicial effect.
The error was not harmless. Although the remaining evidence was legally sufficient, the case largely depended on whether the jury believed Knotts or the alleged victim, without independent or forensic corroboration. The State introduced the convictions during cross-examination, emphasized them in closing argument, and obtained no limiting instruction, creating a substantial risk that the jury rejected Knotts’s testimony because of his criminal history. The court reversed the judgment and remanded for a new trial.
Key Takeaways
- A criminal defendant does not place a peaceful character trait at issue merely by denying charged conduct or related allegations.
- The prosecution may not create its own basis for character rebuttal by asking a defendant about character and then treating the answer as opening the door to specific prior misconduct.
- A testifying criminal defendant generally may be impeached with prior convictions only when the crimes involved perjury or false swearing, and convictions more than ten years old face additional safeguards.
Why It Matters
The decision reinforces strict limits on using a criminal defendant’s prior convictions before a jury. Prosecutors cannot circumvent those limits by relabeling inadmissible convictions as character rebuttal or general impeachment evidence.
The ruling also illustrates why evidentiary errors can require retrial even when the remaining evidence is sufficient to convict. When a case turns on competing witness accounts, repeated references to an accused person’s unrelated criminal history may improperly determine whom the jury believes.