State of Missouri, Plaintiff/Respondent v. William Adams
2014 Mo. App. LEXIS 1037
Mo. Ct. App.2014Background
- William Adams appeals his first-degree tampering conviction following a jury trial, where he was sentenced as a prior and persistent offender to nine years' imprisonment.
- The State alleged Adams unlawfully operated a Chevrolet pickup without the owner’s consent after it was taken from County Asphalt’s fenced lot.
- Officers chased Adams after he fled when questioned and found two keys in his pocket: one for the Chevy truck and one for a Ford truck later found stolen.
- Bolt cutters were found in the Chevy truck; Adams claimed a man named “Red” gave him a key ring with three keys and that he was merely returning the truck.
- Adams testified that he did not know the Chevy truck was stolen and that he had permission to drive it; the jury acquitted on the stealing charge but convicted on first-degree tampering.
- Adams challenges two evidentiary rulings: (1) sustaining the State’s objection to cross-examination about money found on Adams and (2) admitting evidence of uncharged misconduct regarding the other stolen truck.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Cross-examination on money seized | State argues rebuttal scope, not error in cross-exam. | Adams claims money within scope of rebuttal would rebut gas-out-of-trap theory. | No abuse of discretion; properly limited rebuttal evidence. |
| Evidence of uncharged misconduct (other stolen truck) | Evidence relevant to rebut Adams’s denial and deception about keys. | Uncharged acts prejudicial and improper propensity evidence. | No abuse of discretion; minimal prejudice given overwhelming evidence of guilt. |
Key Cases Cited
- State v. Hatch, 54 S.W.3d 623 (Mo. App. W.D. 2001) (evidentiary relevance and balancing of probative value vs. prejudice)
- State v. Simmons, 944 S.W.2d 165 (Mo. Banc 1997) (scope of trial court’s discretion on rebuttal evidence)
- State v. Petty, 967 S.W.2d 127 (Mo. App. E.D. 1998) (exceptions to the general rule against uncharged misconduct)
- State v. Perryman, 851 S.W.2d 776 (Mo. App. E.D. 1993) (probative value vs. prejudicial effect in uncharged acts)
- State v. Pettit, 976 S.W.2d 585 (Mo. App. W.D. 1998) (necessary balancing of prejudicial effect with probative value on uncharged acts)
- State v. Danikas, 11 S.W.3d 782 (Mo. App. W.D. 1999) ( prejudice standard for admission of evidence)
- State v. Johnson, 207 S.W.3d 24 (Mo. banc 2006) (prejudice standard for evidentiary rulings)
- State v. Williams, 976 S.W.2d 1 (Mo. App. W.D. 1998) (prejudice assessment in uncharged misconduct)
- Storey v. State, 175 S.W.3d 116 (Mo. banc 2005) (requirements for point relied on on appeal)
- DeClue, 128 S.W.3d 864 (Mo. App. S.D. 2004) (limits on cross-examination)