State of Missouri v. Christopher L. Collings
2014 Mo. LEXIS 202
| Mo. | 2014Background
- Collings was convicted of first-degree murder of Rowan Ford and sentenced to death after a jury recommendation; Missouri Supreme Court reviews for proportionality.
- Rowan Ford disappeared November 3–4, 2007; Collings, Spears, and Mahurin were last known to be with Rowan and became persons of interest.
- Investigators obtained and reviewed multiple statements from Collings; Miranda warnings were given and waivers signed; polygraph/CVSA testing occurred with consent.
- Rowan’s body was found in a Fox Cave sinkhole with evidence of rape and ligature strangulation; autopsy showed extensive injuries and DNA/foreign hairs were collected.
- Collateral evidence included burns, destruction of items, and a series of videotaped and videotaped-like statements; the State sought suppression of some statements and evidence.
- The defense moved to suppress all statements and physical evidence; the circuit court denied, and trial proceeded with guilt and penalty phases resulting in a death sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of Collings' statements | Collings was coerced; Miranda rights violated; two-step questioning occurred. | Statements were voluntary; rights were properly administered; no improper coercion. | Statements were voluntary; suppression denied. |
| Admissibility of other evidence at suppression | Cross-cutting evidence (polygraph, CVSA, non-robust acts) relevant to voluntariness. | Inadmissible or prejudicial; inconsistent rulings. | Rulings were within circuit court discretion; no plain error. |
| Deliberation element for first-degree murder | Evidence supported planning and deliberate killing after rape; kidnapping and concealment show deliberation. | Some testimony suggests a sudden reaction; lack of long-term contemplation. | Evidence supports deliberate murder; conviction affirmed. |
| Admissibility and weight of physical evidence | Burn pile cord, ashes, pubic hairs, and DNA-related evidence were probative. | Some items were prejudicial or mischaracterized; weight rather than admissibility issue. | Admission proper; no reversible error. |
| Proportionality and sufficiency of aggravating factors | Aggravators supported death sentence; cruelty, torture, and witness-corroption factors. | Mitigating factors outweigh aggravators; sentence disproportionate. | Death sentence proportional; affirmed. |
Key Cases Cited
- State v. McFadden, 369 S.W.3d 727 (Mo. banc 2012) (prejudice-based standard of review for death sentences)
- Missouri v. Seibert, 542 U.S. 600 (U.S. 2004) (two-step interrogation framework)
- State v. Gaw, 285 S.W.3d 318 (Mo. banc 2009) (custodial interrogation and Miranda analysis in Seibert context)
- Deck v. State, 303 S.W.3d 527 (Mo. banc 2010) (plain error and evidence-admissibility framework in capital cases)
- Kansas v. Marsh, 548 U.S. 163 (U.S. 2006) (burden-shifting in capital sentencing compatible with due process)