June P. Morgan

In State v. Sherman, the appellant was convicted of attempted rape after the trial court excluded evidence that the complainant had told another person hours earlier that a different individual had raped her. The Missouri Court of Appeals reversed the conviction and remanded for a new trial, finding the excluded evidence admissible under an exception in the state's rape shield statute. The court reasoned that the evidence concerned immediate surrounding circumstances of the alleged crime and qualified as res gestae because it involved closely connected events in time and place that formed part of the overall transaction. The trial court's decision to exclude the evidence based on credibility assessments was held erroneous, as the jury is responsible for weighing witness testimony.

criminal lawprocedure

In State v. Ray, the defendant was convicted of forcible rape under Missouri law after a trial in which the court excluded evidence that the complainant had engaged in sexual activity with one of the other alleged participants the night before the charged incident. The defendant argued that this evidence was relevant to the issues of consent and the complainant's ability to perceive and recall events, given her intoxication and the similar circumstances on both nights. The Missouri Supreme Court reversed the conviction and remanded the case, holding that the evidence should have been admitted under the rape shield statute because it was probative of material facts under the statute's relevance provision and exceptions, rather than deciding the constitutional challenge. The court emphasized that the trial judge must allow evidence that logically tends to prove or disprove key issues like consent when the statutory criteria are met.

criminal lawprocedure

The case involved Winford L. Stokes, who was convicted by a jury of capital murder in the death of Pamela R. Benda and sentenced to death under Missouri statutes. On direct appeal, the Supreme Court of Missouri affirmed the conviction and sentence after reviewing the trial record, which included evidence of the victim's strangulation, the defendant's fingerprints at the scene, his possession of the victim's car and watch, and his prior convictions. The court upheld the jury's findings on multiple statutory aggravating circumstances, such as a history of serious assaultive convictions, murder for monetary gain, torture or depravity, and escape from custody, while rejecting claims of error in evidentiary rulings and sentencing procedures. A separate opinion criticized the timeliness of notice regarding aggravating circumstances but did not alter the outcome.

criminal lawprocedure

This case involved the conviction of the appellant for forcible rape and kidnapping after he was acquitted of sodomy. The central issue was whether evidence of the complainant's sexual relations with her boyfriend shortly before the alleged incident should have been admitted at trial under the rape shield statute. The trial court excluded the evidence, but the appellate court reversed the convictions and remanded the case, holding that the evidence qualified as evidence of the immediate surrounding circumstances of the crime and was relevant to the issue of consent.

criminal lawprocedure

The case involved Patrick Trimble, who was tried and convicted by a jury of capital murder under Missouri statutes for strangling fellow inmate Jerry Everett in the St. Charles County jail in November 1979. Trimble had been awaiting trial on other serious charges and had announced plans to commit capital murder, after which he subjected Everett to a week of physical and sexual abuse before killing him and attempting to stage the scene. The jury assessed punishment at death, and the Missouri Supreme Court affirmed the conviction and sentence after reviewing the trial record for errors and conducting the statutory proportionality review. The court concluded that the evidence supported the verdict, that aggravating circumstances were present, and that the death penalty was neither excessive nor disproportionate to similar cases.

criminal lawprocedure

In State v. Brown, the defendant was convicted of three counts of forcible rape and two counts of forcible sodomy and sentenced as a persistent offender. The primary issue on appeal was whether Missouri's rape shield statute, § 491.015, which generally bars evidence of a complainant's prior sexual conduct, violated the defendant's Sixth Amendment confrontation rights by preventing him from introducing evidence of the complainant's reputation for indiscriminate sexual activity or specific prior acts to show consent or motive to falsify. The Missouri Supreme Court affirmed the convictions, holding the statute constitutional on its face because prior sexual conduct is not per se relevant to consent or credibility, the statute's presumption of irrelevance with limited exceptions reasonably balances probative value against prejudice and policy interests in protecting victims, and exclusion of such evidence does not deprive a defendant of a fair trial.

criminal lawprocedure