State of Missouri v. William Edwards
2017 Mo. App. LEXIS 109
| Mo. Ct. App. | 2017Background
- On July 5, 2015 Sgt. Paul Anderson pursued William Edwards after Edwards attempted to evade a DWI checkpoint, driving at high speeds and running red lights.
- A high-speed chase ended when Edwards’ vehicle and another vehicle collided at an intersection; the victims were occupants of the other vehicle (Pierra Hathaway and Shawnte Champ).
- Hathaway suffered catastrophic brain and spinal injuries and remained with severe cognitive and physical impairment; Champ testified to multiple traumatic injuries (lacerated spleen, broken wrist and jaw, head injuries).
- Edwards was tried without a jury and convicted of two counts of second-degree assault (one for each victim), two counts of armed criminal action (one accompaniments to each assault), resisting arrest, and driving while revoked; total effective sentence 30 years.
- On appeal Edwards challenged: (1) double jeopardy (two assault convictions from a single act), (2) a purported variance between the indictment and proof about which vehicle struck which, and (3) sufficiency of the evidence on causation for each victim’s injuries.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Double jeopardy from two assault convictions | State: Separate convictions allowed when one act harms multiple victims | Edwards: Single act cannot support multiple assault convictions; violates double jeopardy | Affirmed — convictions for separate victims are distinct offenses under the statute and precedent |
| Variance between indictment and proof (which car struck which) | State: Indictment charged reckless causing of serious injury; specific wording was surplusage | Edwards: Indictment alleged he struck victims’ car; evidence showed victims’ car hit him — material variance | Affirmed — specific phrasing was surplusage; no prejudice to defense, conviction focuses on causation, not which vehicle struck which |
| Sufficiency of evidence as to Hathaway’s injuries (causation) | State: Video, photographs, hospital condition, witness testimony supported proximate causation | Edwards: No expert proof linking collision to Hathaway’s brain/spinal injuries; timing unclear | Affirmed — factfinder could reasonably infer collision proximately caused Hathaway’s injuries from the record |
| Sufficiency of evidence as to Champ’s injuries (causation) | State: Champ’s own testimony and photographs tied injuries to the accident | Edwards: Insufficient proof that collision caused Champ’s injuries | Affirmed — Champ’s testimony and photos were sufficient for the trier of fact to find causation |
Key Cases Cited
- State v. Smith, 456 S.W.3d 849 (Mo. banc 2015) (same conduct harming multiple victims permits separate convictions for each victim)
- State v. Whitley, 382 S.W.2d 665 (Mo. 1964) (statute contemplates as many offenses as there are human beings killed in single act)
- State v. Bowles, 754 S.W.2d 902 (Mo. App. E.D. 1988) (single act affecting multiple persons can constitute multiple assault offenses)
- State v. Porter, 464 S.W.3d 250 (Mo. App. E.D. 2015) (look to statutory elements when assessing double jeopardy/multiple punishment issues)
- State v. Neher, 213 S.W.3d 44 (Mo. banc 2007) (preservation rules for constitutional claims; plain error review when discernible on face of record)