State of Missouri v. Christopher Eric Hunt, 2014 Mo. LEXIS 369

Deputy Hunt entered the trailer during an arrest operation lacking a search warrant for the trailer.
The arrest was based on two felony warrants for manufacture of methamphetamine and child endangerment.
Hunt kicked in a porch door and several officers entered, secuing evidence of a mobile meth lab.
Hunt was convicted by jury of first-degree burglary, second-degree property damage, and third-degree assault.
The State challenged the sufficiency of the burglary and property-damage evidence and the instructions on assault.
The court granted transfer and reversed the convictions, remanding for new proceedings on key issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the State prove first-degree burglary beyond a reasonable doubt?	Hunt knew no privilege to enter.	State argued no reasonable belief suspect inside; entry lawful if believe inside.	Conviction reversed for insufficient evidence.
Was the second-degree property damage conviction supportable under the entry privilege?	Hunt acted under 544.200 privilege to arrest.	Damage occurred during lawful entry; no predicate crime needed for property damage.	Conviction reversed; privilege foreclosed liability.
Were the jury instructions on assault plain error?	Instructions misdirected about officer authority and reasonable force.	Instructions should have reflected statutory standards and not asked jurors to decide officer status.	Conviction for third-degree assault reversed and remanded for a new trial.
Was excluded testimony about reasonable force preserved for appeal?	Clay would testify about training and force justification.	Offer of proof was insufficiently specific; not preserved.	Plain-error review declined; no reversal on this issue.
Did the court err by defining assault without officer context and by misdefining lawfulness of arrest?	Burglary and assault definitions improper for officer-context.	Instructions should align with Missouri law on unlawful entry and lawful arrest.	Plain-error review found; instructions defective; reversal and remand.

State v. Nash, 339 S.W.3d 500 (Mo. banc 2011) (sufficiency review limits and standard of review for criminal conduct)
State v. Cooper, 215 S.W.3d 123 (Mo. banc 2007) (two elements of burglary: unlawfully entering and intent to commit a crime)
State v. Chandler, 635 S.W.2d 338 (Mo. banc 1982) (entry privilege and knowledge of lack of privilege)
State v. Langdon, 110 S.W.3d 807 (Mo. banc 2003) (standard for evidentiary inferences and knowledge mens rea)
United States v. Boyer, 574 F.2d 951 (8th Cir. 1978) (knock-and-announce and officer entry duties (Mo. law analogies))
State v. Lovelady, 432 S.W.3d 187 (Mo. banc 2014) (considerations of reasonableness in entry and force)
State v. Ousley, 419 S.W.3d 65 (Mo. banc 2013) (plain-error standards for instructional error)
State v. Shockley, 410 S.W.3d 179 (Mo. banc 2013) (evidence and trial-discretion review of admitted/excluded testimony)
Moore v. Ford Motor Co., 332 S.W.3d 749 (Mo. banc 2011) (offers of proof and preservation of error)
Baumruk, 280 S.W.3d 600 (Mo. banc 2009) (plain-error standard for criminal appeals)