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