State v. Bartlik, 363 S.W.3d 388

Detective Meyer learned from a confidential informant that Bartlik was selling heroin.
Two controlled buys occurred: July 20, 2009, in a parking lot, with heroin handed to the detective via the informant and $100 exchanged.
A second buy occurred August 4, 2009, with Bartlik handing heroin to the informant, who handed it to the detective for $100.
Bartlik moved pretrial to disclose the confidential informant’s identity, arguing the informant was a material witness and the right to confrontation would be affected.
The trial court denied disclosure; the informant was not called at trial; on appeal, procedural timelines and plain-error standards were discussed.
The appellate court affirmed the judgment, holding the failure to disclose was not outcome-determinative under plain-error review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the failure to disclose the informant was plain error.	Bartlik contends disclosure was necessary to secure a fair trial.	Bartlik argues nondisclosure violated confrontation and due process rights.	No plain-error reversal; not outcome-determinative.
Whether the issue was properly preserved for review given new-trial timing rules.	State did not waive preservation concerns; issue should be reviewable.	Defendant did not timely raise the issue in a motion for new trial.	Issue not preserved; review limited to plain-error analysis.

State v. Dowell, 25 S.W.3d 594 (Mo.App. W.D.2000) (informant identity may be disclosed depending on circumstances)
State v. Myers, 997 S.W.2d 26 (Mo.App.1999) (burden on defendant to show need for disclosure; balancing test)
State v. Rollie, 962 S.W.2d 412 (Mo.App.1998) (informant privilege and nondisclosure considerations)
State v. Langston, 229 S.W.3d 289 (Mo.App.2007) (Rule 29.11(b) new-trial time limits are mandatory)
State v. Young, 230 S.W.3d 30 (Mo.App.2007) (plain-error review limitations for failure to disclose)