State of Missouri v. Timothy L. Boykins, 2015 Mo. App. LEXIS 881

Defendant Timothy Boykins (aka “Y.G.”) convicted by jury of first-degree murder and armed criminal action for the November 2012 shooting death of Nathan Reed; sentence: life without parole plus life. Appeal followed.
Key eyewitnesses: Dante Jones (inside a garage where a dice game was occurring) testified he saw Boykins chase and shoot Reed and heard Boykins warn him not to tell; Jones knew Boykins from the neighborhood. Corey Williams saw someone he recognized as Y.G. running away wrapping a pistol in a hoodie shortly after shots.
Detective Steven Kaiser testified the investigation focused on Boykins after receiving multiple anonymous tips identifying him as the shooter; Williams and Jones later provided statements and identified Boykins in photo arrays.
Defense objected pretrial and at trial to the detective’s testimony recounting anonymous callers’ identifications as inadmissible hearsay and Confrontation Clause violations.
Trial court admitted the detective’s testimony about the anonymous tips; on appeal Boykins argued that testimony was hearsay offered for its truth rather than merely to explain police conduct.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether testimony about anonymous tips identifying Boykins was inadmissible hearsay and violated the Confrontation Clause	State: tips were admissible to explain why police focused investigation on Boykins	Boykins: tips were offered for their truth (to prove he was shooter) and were inadmissible hearsay and testimonial (Confrontation Clause)	Court: admission was erroneous (tips implicated defendant and were not necessary to explain police conduct) but error was harmless beyond a reasonable doubt; conviction affirmed

State v. Taylor, 373 S.W.3d 513 (Mo. App. E.D.) (standard for reviewing evidentiary rulings and confrontation concerns)
State v. Brooks, 618 S.W.2d 22 (Mo. banc) (out-of-court statements admissible to explain police conduct for background/continuity)
State v. McGee, 284 S.W.3d 690 (Mo. App. E.D.) (limits on using investigative narrative to introduce inculpatory out-of-court statements)
State v. Nabors, 267 S.W.3d 789 (Mo. App. E.D.) (caution against backdoor admission of informant statements; harmless-error analysis)
State v. Garrett, 139 S.W.3d 577 (Mo. App. S.D.) (permissible to say investigation focused on defendant "upon information received" without repeating informant statements)
State v. Kirkland, 471 S.W.2d 191 (Mo.) (prejudice where hearsay provided sole identification evidence)
State v. Shigemura, 680 S.W.2d 256 (Mo. App. E.D.) (hearsay prejudicial where other evidence of guilt was weak)
State v. Robinson, 111 S.W.3d 510 (Mo. App. S.D.) (jury question referencing informant statement can show prejudice)
State v. Barriner, 34 S.W.3d 139 (Mo. banc) (standard for harmless-error review of erroneously admitted evidence)