STATE OF MISSOURI v. TOMMY R. MORRIS, SD36716

Police under undercover narcotics surveillance observed Tommy R. Morris engage in a suspected controlled-substance transaction from his car at a Price Cutter parking lot.
Officers attempted to box in Morris; a detective ordered him to show his hands but Morris fled, striking a grocery cart while exiting the lot.
Morris continued a high-speed flight from police, at times exceeding twice the speed limit, for a roughly 3.4-mile route. He ran a red light and collided with a vehicle driven by D.S., who died at the scene.
Morris was indicted for attempted delivery and delivery of a controlled substance (class C felonies) and second-degree murder (class A), alleging the killing occurred during Morris’s ‘‘immediate flight’’ from the felonies.
After a bench trial the court convicted Morris on all counts, denied his motions for judgment of acquittal, and sentenced him (concurrent terms). He appealed only the sufficiency of evidence for the second-degree murder conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there was sufficient evidence that Victim was killed "as a result of the immediate flight" from the charged felonies for second-degree murder under Mo. Rev. Stat. §565.021.1(2)	The State argued Morris’s flight from the Price Cutter was continuous and uninterrupted until the fatal collision 3.4 miles away (≈45 seconds after losing sight), so the killing was the result of the immediate flight.	Morris argued "immediate" requires a near-instant temporal nexus; the collision miles and minutes away (and officers’ temporary loss of visual contact/deactivation of lights) broke immediacy, so the killing was not the result of immediate flight.	Court construed "immediate flight" to mean continuous/uninterrupted flight (no intervening agency); evidence showed continuous flight culminating in the crash, so sufficiency upheld and conviction affirmed.

State v. McQuary, 173 S.W.3d 663 (Mo. Ct. App. 2005) (standard for reviewing motions for judgment of acquittal equals sufficiency review)
State v. Hunt, 451 S.W.3d 251 (Mo. banc 2014) (review requires viewing evidence in light most favorable to verdict; no reweighing)
State v. Perry, 275 S.W.3d 237 (Mo. banc 2009) (statutory interpretation reviewed de novo)
State v. Gilmore, 508 S.W.3d 132 (Mo. Ct. App. 2016) (undefined statutory words given plain meaning, supplemented by dictionary if needed)
Kehlenbrink v. Director of Revenue, 577 S.W.3d 798 (Mo. banc 2019) (statutory words must be read in context)
State ex rel. Goldsworthy v. Kanatzar, 543 S.W.3d 582 (Mo. banc 2018) (plain meaning determined from statute’s context)
State v. Stewart, 113 S.W.3d 245 (Mo. Ct. App. 2003) (give effect to legislature’s intent by examining plain language)
State v. Goddard, 34 S.W.3d 436 (Mo. Ct. App. 2000) (language should be plain and clear to a person of ordinary intelligence)