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State of Missouri v. William Darrell Joyner
458 S.W.3d 875
| Mo. Ct. App. | 2015
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Background

  • Joyner appealed a conviction for aggravated stalking in a minor-related case.
  • Victim was a twelve-year-old female; Joyner was a 45-year-old male frequenting the same church and invited to live with the family.
  • The State presented acts (letters, following, observing, and hospital-area presence) as a course of conduct to prove stalking.
  • Prior to trial, Joyner’s status as a registered sex offender and related convictions were excluded by in limine orders.
  • The State elicited testimony that the victim feared Joyner because of his sex-offender status, and closing argument emphasized that status.
  • The trial court admitted the testimony over objection, and on appeal the court reverses and remands for a new trial on grounds of improper admission and prejudice.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether admission of the victim’s fear based on Joyner’s sex-offender status was improper Joyner Joyner Yes; admission was abuse of discretion and outcome-determinative.
Whether the State could rely on victim’s knowledge of Joyner’s status to prove intent to harass Joyner Joyner No; state-of-mind evidence not essential element; error reversed.

Key Cases Cited

  • State v. McFadden, 369 S.W.3d 727 (Mo. banc 2012) (admissibility and error standard for evidentiary rulings in criminal trials)
  • State v. Oerly, 446 S.W.3d 304 (Mo. App. W.D. 2014) (abuse of discretion standard for evidentiary decisions)
  • Barriner, 34 S.W.3d 139 (Mo. banc 2000) (outcome-determinative prejudice factors for improperly admitted evidence)
Read the full case

Case Details

Case Name: State of Missouri v. William Darrell Joyner
Court Name: Missouri Court of Appeals
Date Published: Apr 21, 2015
Citation: 458 S.W.3d 875
Docket Number: WD76857
Court Abbreviation: Mo. Ct. App.