State of Missouri v. Daniel D. Hartman, 2016 Mo. LEXIS 68

Background

On July 5, 2012, the victim was shot to death during a botched home robbery; three bullets were recovered from the scene.
Hartman was charged with first‑degree murder, armed criminal action, and first‑degree burglary; co‑defendants testified pursuant to plea deals and one co‑defendant (Jonathan) invoked the Fifth.
Defense sought to call Harlin King to testify that Jonathan spontaneously confessed to King shortly after the killing, admitting he shot the victim three times.
The trial court excluded King’s testimony as hearsay; Hartman proceeded to verdict and was convicted (later the court entered convictions for second‑degree murder and armed criminal action and sentenced Hartman to concurrent life terms).
On appeal to the Missouri Supreme Court, Hartman argued exclusion of King’s testimony violated his due process right to present potentially exculpatory evidence under the Chambers hearsay exception.
The Missouri Supreme Court held the exclusion violated Hartman’s due process rights, vacated the convictions, and remanded for a new trial.

Issues

Issue	Plaintiff's Argument (Hartman)	Defendant's Argument (State)	Held
Admissibility of out‑of‑court confession (Chambers exception)	King’s testimony was a spontaneous, reliable admission against Jonathan’s penal interest and thus admissible under Chambers; it could exonerate Hartman.	The statement was hearsay and inadmissible; allowing it was improper.	Court: Exclusion was error — King’s proffer met Chambers’ three indicia of reliability and could exonerate Hartman; testimony should have been admitted.
Prejudice from exclusion	Excluding reliable, potentially exculpatory testimony prejudiced Hartman’s right to a fair trial.	Any error was harmless because other testimony placed Jonathan among those who claimed to have shot the victim and the jury heard similar statements.	Court: Error was prejudicial; reasonable probability outcome affected; vacated convictions and remanded.
Applicability of accomplice-liability instructions if confession admitted	(Implicit) Admission of Jonathan’s confession would have allowed jury to credit alternate shooter and acquit Hartman of first‑degree murder.	Even if confession admitted, state could obtain accomplice liability instructions, so admission would not necessarily exonerate Hartman.	Court: Because King’s confession implicated Jonathan alone and matched corroborating facts, its exclusion deprived Hartman of a defense; admission could have led to acquittal on first‑degree murder.
Whether to reach closing‑argument claim on adverse inference	Hartman argued state urged jury to infer guilt from omission of excluded testimony.	State defended closing argument; trial rulings cured or made point moot.	Court: Did not decide adverse‑inference claim on appeal because it may not recur on remand.

Key Cases Cited

Chambers v. Mississippi, 410 U.S. 284 (1973) (constitutional due‑process hearsay exception for trustworthy out‑of‑court statements that exonerate the accused)
State v. Blankenship, 830 S.W.2d 1 (Mo. banc 1992) (discussing Chambers indicia of reliability)
State v. Turner, 623 S.W.2d 4 (Mo. banc 1981) (statements against interest that would exonerate the accused should not be excluded when reliable)
State v. Hart, 404 S.W.3d 232 (Mo. banc 2013) (juvenile sentencing and related procedural treatment cited for sentencing posture)
State v. McFadden, 369 S.W.3d 727 (Mo. banc 2012) (reversal for evidentiary error requires showing of prejudice)
State v. Gilmore, 681 S.W.2d 934 (Mo. banc 1984) (error harmless where jury received the gist of excluded testimony)
State v. Wells, 305 S.W.2d 457 (Mo. 1957) (exclusion not prejudicial when same or substantially similar evidence is otherwise admitted)