State of Missouri v. Marcus Simms, WD83422

Background

On April 30, 2014 Michelle Boldridge was found stabbed to death in the couple’s apartment; Simms’s DNA matched blood at the scene and on a weapon; he was charged with first‑degree murder, armed criminal action, and first‑degree tampering with a motor vehicle.
Pretrial: multiple continuances were requested over years (including defense counsel’s cancer treatment); the court ordered a Department of Mental Health exam; Dr. Heather McMahon diagnosed an unspecified schizophrenia‑spectrum/psychotic disorder but concluded Simms was competent to stand trial.
At trial Simms intermittently displayed unusual behavior (head hitting the table, appearing to pitch himself forward); defense sought continuances and mistrials on competency and medical‑condition grounds; on‑site medical personnel found no emergency.
The court found Simms competent based on the psychiatric evaluation(s), its observations, and jail/medical records; defense offered no medical evidence refuting the competency findings.
Simms testified coherently in his own defense (describing an alleged masked intrusion), was cross‑examined about his efforts to get help for Boldridge, and was convicted on all counts; sentences were consecutive, including life without parole for murder.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Simms)	Held
Denial of continuance on morning of trial (Point I)	Competency already determined; long pretrial preparation; alleged refusal to meet with counsel was Simms’s choice and did not justify last‑minute delay	Needed more time because Simms had psychiatric diagnosis, refused weekend visits, and could not effectively assist counsel	Denial affirmed; claim not preserved (reviewed for plain error) and no plain error shown — court had competent findings and no showing extra time would cure any prejudice
Denial of continuance/mistrial after first disruptive incident (head hitting table) (Point II)	Pretrial psychiatric exam found Simms competent; on‑site medical staff found no emergency; trial court observed conduct and reasonably concluded Simms was willfully acting	Simms was mentally/physically unfit to continue; behavior showed incapacity to assist and risked prejudice	Denial affirmed; substantial evidence supported competence (expert opinions, court observations, medical checks), and Simms failed to meet burden to prove incompetence
Denial of mistrial after repeated disruptive behavior (pulling forward/pitching) (Point III)	Same as Point II: no new medical proof, prior competency finding, deputies and medical staff reported no emergency; court may remove disruptive defendant	Behavior demonstrated incompetence and justification for mistrial or further evaluation	Denial affirmed; trial court acted within discretion — it could rely on evaluations and its own observations; removing defendant rather than mistrial was permissible
Overruled objections to repeated cross‑examination about whether Simms tried to help victim (Point IV)	Questions were probative of deliberation and impeachment of Simms’s testimony that he sought help; admissible and within broad cross‑examination scope	Repetitive, argumentative, prejudicial; no impeachment purpose because other witnesses already testified Simms sought help	Denial of objection affirmed; questions relevant to deliberation and impeachment, cumulative but not prejudicial enough to deny fair trial

Key Cases Cited

Dusky v. United States, 362 U.S. 402 (1960) (established competency standard: factual and rational understanding and ability to consult with counsel)
State v. Wise, 879 S.W.2d 494 (Mo. banc 1994) (competency standard under Missouri law)
State v. Anderson, 79 S.W.3d 420 (Mo. banc 2002) (defendant presumed competent; burden to prove incompetence)
State v. Frezzell, 958 S.W.2d 101 (Mo. App. W.D. 1998) (burden on accused to show incompetence)
Maggio v. Fulford, 462 U.S. 111 (1983) (deference to trial court competency findings based on face‑to‑face evaluations)
State v. Strong, 142 S.W.3d 702 (Mo. banc 2004) (failure to seek medical help may support inference of deliberation)
State v. Brown, 517 S.W.3d 617 (Mo. App. E.D. 2017) (continuance required where defendant’s inability to communicate prevented preparation of a specific defense)
State v. Mays, 501 S.W.3d 484 (Mo. App. W.D. 2016) (broad trial court discretion on evidentiary rulings; prejudice—not mere error—required for reversal)
State v. Kemp, 212 S.W.3d 135 (Mo. banc 2007) (review of evidentiary rulings for prejudice rather than mere error)