State of Missouri v. Andrew Barnett, 577 S.W.3d 124

Background

Barnett was convicted by a jury of first-degree assault and armed criminal action after an altercation outside a bar in St. Louis in which the victim was found stabbed.
Evidence: earlier in the night the victim had provoked Barnett and urged him to fight; later the victim approached Barnett threateningly; bartenders ejected both men.
After leaving the bar, Barnett stopped to urinate; the victim approached from behind, shouted threats including “now you’re going to die,” and Barnett observed a “metal and shiny” object moving toward his face.
Barnett testified he knocked the object-handling hand away, shoved the victim to the ground, and left; he later denied stabbing the victim when questioned by police.
At trial Barnett requested a self-defense instruction; the state objected because Barnett had denied committing the stabbing. The trial court refused the self-defense instruction, submitted only first-degree assault and mitigating heat of passion, and the jury returned guilty verdicts.
The Missouri Supreme Court vacated the judgment and remanded, holding substantial evidence supported submission of a self-defense instruction and overruling prior cases implying a defendant’s contradictory testimony can bar such instructions.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Barnett was entitled to a self-defense instruction	State: Not entitled because Barnett denied committing the stabbing and the evidence of self-defense was not introduced by the State or third parties	Barnett: Substantial evidence (victim’s threats and a metal object advancing toward his face) supported self-defense, regardless of his denial	Court: Self-defense instruction required; substantial evidence supported it and defendant’s contradictory testimony does not bar the instruction
Whether the source of evidence (who introduced it) matters for instruction entitlement	State: Instruction only proper if evidence injected by State or third-party witnesses	Barnett: Source irrelevant; court must consider all admitted evidence in defendant-favor when assessing instruction entitlement	Court: Source is irrelevant; Bidstrup rule controls — consider all admitted evidence regardless of who introduced it
Whether a defendant’s testimony inconsistent with the requested instruction prevents submission	State: Defendant’s denial negates entitlement	Barnett: Inconsistent testimony does not preclude instruction if other evidence supports it	Court: A defendant may obtain an instruction even when his testimony contradicts it; jury decides credibility
Whether prior precedent limiting instructions should remain good law	State: Relied on Wright/Baker line to deny instructions when evidence came only from defendant	Barnett: Those cases are inconsistent with Bidstrup and should not be followed	Court: Overruled cases that conflicted with Bidstrup; reaffirmed that substantial evidence (even from defendant) requires submission of the instruction

Key Cases Cited

State v. Bidstrup, 140 S.W. 904 (Mo. 1911) (court must submit an instruction when substantial evidence supports it regardless of who offered the evidence)
State v. Cole, 377 S.W.2d 306 (Mo. 1964) (court views evidence in the light most favorable to defendant when deciding instruction entitlement)
State v. Jackson, 433 S.W.3d 390 (Mo. banc 2014) (jury, not court, is the factfinder when evidence presents conflicting versions)
State v. Bruner, 541 S.W.3d 529 (Mo. banc 2018) (self-defense instruction required when substantial evidence supports it even if inconsistent with defendant’s testimony)
State v. Smith, 456 S.W.3d 849 (Mo. banc 2015) (defines ‘supported by the evidence’ as substantial evidence standard)
State v. Wright, 175 S.W.2d 866 (Mo. 1943) (historic dicta misread to require evidence be offered by State or third parties; Court diagnoses and limits that dictum)
State v. Baker, 277 S.W.2d 627 (Mo. 1955) (followed Wright’s dicta; Court overrules its reasoning insofar as it conflicts with Bidstrup)