State v. Bowman, 337 S.W.3d 679

Background

Bowman was convicted of first-degree murder for Velda Rumfelt's 1977 killing and sentenced to death following a jury recommendation.
Two of the jury-found aggravating circumstances were based on vacated Illinois murder convictions later reversed on appeal.
DNA evidence linked Bowman to Rumfelt's underwear; the semen DNA profile frequency was extremely small.
Bowman had prior Illinois murder convictions (vacated on post-conviction review), which the State sought to rely on in penalty.
The defense moved to limit victim-impact and other evidence during penalty; the trial court admitted extensive aggravating and other evidence.
The Missouri Supreme Court conducted an independent review of the death penalty strength and ultimately reversed the death sentence on due to invalid aggravating factors.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
DNA profile admissibility under Fourth Amendment/IGPA	Bowman; Fourth Amendment and IGPA protect against disclosure of genetic data to assess a different crime.	State; lawfully obtained DNA may be used in unrelated investigations; consent for initial search does not bar later use.	Admissibility affirmed; use of lawfully obtained DNA in unrelated case does not violate Fourth Amendment/IGPA.
Admissibility of alternative perpetrator evidence	Bowman; evidence tying Kevin Kiger to related murders should be admitted as an alternate perpetrator.	Kiger evidence lacks direct connection to Rumfelt's murder; not admissible as direct alternative perpetrator evidence.	Trial court did not err in excluding the alternative-perpetrator evidence.
Sufficiency of the guilt evidence	Bowman contends evidence does not reasonably support guilt beyond a reasonable doubt.	Evidence including DNA in underwear, eyewitness identification, and circumstantial factors suffices.	Guilt supported by the record; judgment of acquittal not warranted.
Validity of aggravating factors in penalty phase	Two vacated Illinois murders used as aggravators prejudicially influenced the penalty.	Prior convictions (even vacated) and related acts are permissible non-statutory aggravators.	Death sentence reversed because invalid weighting of vacated convictions tainted the penalty.
Strength of evidence for death penalty on independent review	Strength of evidence supports death given DNA and related facts.	Strength of evidence not compelling; the case warrants life imprisonment.	Court concluded the evidence was not sufficiently compelling to justify death; remanded for life imprisonment.

Key Cases Cited

State v. Granado, 148 S.W.3d 309 (Mo. banc 2004) (standard for reversing suppression rulings; de novo Fourth Amendment review)
State v. Sund, 215 S.W.3d 719 (Mo. banc 2007) (Fourth Amendment analysis in DNA cases; scope of consent)
State v. Woods, 284 S.W.3d 630 (Mo. App.2009) (limited appellate review; admissibility of evidence)
State v. Barriner, 111 S.W.3d 396 (Mo. banc 2003) (evidence of alternate perpetrators; balancing probative value vs. prejudice)
State v. Davis, 211 S.W.3d 86 (Mo. banc 2006) (modus operandi analysis; high bar for MO evidence)
State v. Bernard, 849 S.W.2d 10 (Mo. banc 1993) (moda operandi/identity evidence standards)
State v. McFadden, 216 S.W.3d 673 (Mo. banc 2007) (limitations on weighing vacated convictions in death penalties)
State v. Chaney, 967 S.W.2d 47 (Mo. banc 1998) (independent review; strength of evidence in capital cases)
State v. Langdon, 110 S.W.3d 807 (Mo. banc 2003) (standard for reviewing guilt in capital cases; independent review requirements)
State v. Franklin, 969 S.W.2d 743 (Mo. banc 1998) (strength of evidence as a factor in proportionality review)
State v. Bannister, 680 S.W.2d 141 (Mo. banc 1984) (not excessive or disproportionate considering crime and strength of evidence)
Gatewood, 786 F.2d 821 (8th Cir. 1986) (relationship between chain-of-custody and admissibility)