State of Missouri v. Andrea Shaunte Straughter, SC99170

On May 17, 2018, Andrea Straughter drove Nicholas Ward to his ex-girlfriend Markysha Randell’s home; an argument ensued and Randell was brandishing a handgun and threatening bystanders.
Randell thrust her arm through Straughter’s open car window and punched Straughter in the face; another person (Jenkins‑Finnie) ran toward the vehicle holding a gun.
Straughter grabbed a gun from the passenger seat and fired at least twice, striking Randell in the abdomen and Jenkins‑Finnie in the foot.
Straughter was charged with two counts of first‑degree assault and two counts of armed criminal action; a jury convicted and the court sentenced her to 10 years.
At trial Straughter requested both a general self‑defense instruction and a “castle doctrine” instruction (deadly force justified to repel unlawful entry into a vehicle); the court gave the general instruction but refused the castle doctrine instruction.
On appeal the Missouri Supreme Court (en banc) reviewed whether substantial evidence entitled Straughter to the castle doctrine instruction and whether refusing it prejudiced her, ultimately vacating the conviction and remanding for a new trial.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Straughter)	Held
Whether substantial evidence supported a castle‑doctrine instruction under §563.031.2(2)	Randell’s arm had exited/was no longer unlawfully in the vehicle by the time Straughter fired, so the statutory entry/remaining/attempt requirement was not met	Randell’s arm entered through the window and the punch and shooting occurred in rapid sequence; viewed favorably to defendant, the unlawful entry and threat were simultaneous with the shooting	Yes — substantial evidence supported the castle doctrine instruction; trial court erred by refusing it
Whether the instructional error prejudiced Straughter (harmless‑error inquiry)	Excluding the instruction was not materially prejudicial because a general self‑defense instruction was given	Castle doctrine permits deadly force in broader circumstances than general self‑defense; its exclusion created a reasonable probability of a different outcome	Yes — exclusion prejudiced Straughter; new trial required
Whether the instructional‑error claim was preserved for appeal despite numbering error in new‑trial motion	The State contended Straughter misidentified the instruction number in her motion	Straughter argued the substance clearly raised the castle doctrine issue at trial and in the motion	Preserved — Court found the request at trial and the motion’s substance sufficient to preserve review

State v. Bruner, 541 S.W.3d 529 (Mo. banc 2018) (standards for requesting jury instructions; view evidence in light most favorable to defendant)
State v. Barnett, 577 S.W.3d 124 (Mo. banc 2019) (defendant entitled to instruction if substantial evidence supports theory)
State v. Westfall, 75 S.W.3d 278 (Mo. banc 2002) (will vacate conviction if failure to submit self‑defense instruction results in prejudice)
State v. Whitaker, 636 S.W.3d 569 (Mo. banc 2022) (recognizing dynamic altercations may preclude parsing discrete instants; view evidence holistically)
State v. Forrest, 183 S.W.3d 218 (Mo. banc 2006) (prejudice for instructional error requires reasonable probability the error affected the outcome)
State v. Clinch, 335 S.W.3d 579 (Mo. App. 2011) (castle doctrine incorporates general self‑defense requirements)
State v. Whipple, 501 S.W.3d 507 (Mo. App. 2016) (same; deadly force under castle doctrine subject to §563.031.1)
State v. Weems, 840 S.W.2d 222 (Mo. banc 1992) (trial court must submit self‑defense instruction if supported by evidence)