State v. Chandler
429 S.W.3d 503
| Mo. Ct. App. | 2014Background
- Defendant (Jeffrey Chandler) was convicted after a bench trial of two counts of second-degree statutory sodomy, one count of second-degree rape, and one count of incest; sentences included three consecutive 7-year terms and one concurrent 4-year term.
- Victim T.C., born 1992, is Defendant’s biological daughter with documented intellectual disability (IQ ~58), IEP, found incapacitated and placed under a probate guardianship; medical and school records indicated limited mental capacity.
- Allegations: sexual intercourse, oral and anal sodomy, digital penetration beginning in adolescence; physical evidence included a semen-stained sheet with Defendant’s DNA.
- Following a school disclosure, interviews and a SAFE exam were conducted by a counselor, a forensic interviewer at the Child Advocacy Center (DVD recorded), and a nurse practitioner; each assessed T.C.’s mental age around 10–13 years.
- The State moved to admit out-of-court statements under Mo. Rev. Stat. § 491.075 (statutory hearsay exception for statements by a child under 14 or a “vulnerable person”); a pretrial hearing and exhibits (IEP, guardianship records) were offered to establish vulnerability.
- Defendant objected that the State failed to prove T.C. met the statutory definition of “vulnerable person” and that admitting the hearsay violated confrontation and fair-trial rights.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility under § 491.075: whether T.C. qualified as a “vulnerable person” | Records and witness testimony (IEP, guardianship, interviewer/nurse assessments) show T.C.’s developmental/mental level met statutory definition | State failed to prove vulnerability; expert proof required; competency to testify undermines vulnerability finding | Trial court not reversed — sufficient evidence (IQ, IEP, probate guardianship, witness estimates) supported finding that T.C. was a vulnerable person |
| Requirement of expert testimony to establish vulnerability | Statute does not require expert proof; testimony and records suffice | Expert testimony was necessary to meet burden | Court held no expert required; statutory framework contemplates vulnerable person may testify |
| Effect of witness competency on vulnerable-person status | Competency to testify does not negate vulnerability under § 491.075 | Competency should “trump” probate finding of incapacity | Court held competency to testify does not preclude designation as a vulnerable person under statute |
| Prejudice from any evidentiary error (bench trial) | Even if admission erred, bench trial presumes judge disregarded inadmissible evidence absent record showing reliance | Admission violated confrontation/fair-trial rights and was prejudicial | No reversible prejudice shown; T.C.’s in-court testimony alone supported convictions; presumptively harmless in bench trial |
Key Cases Cited
- Porras v. State, 84 S.W.3d 153 (Mo. Ct. App. 2002) (standard of review for admission/exclusion under § 491.075)
- Roggenbuck v. State, 387 S.W.3d 376 (Mo. banc 2012) (abuse-of-discretion and evidence-admission standard)
- Davis v. State, 318 S.W.3d 618 (Mo. banc 2010) (abuse-of-discretion framework for evidentiary rulings)
- Austin v. State, 411 S.W.3d 284 (Mo. Ct. App. 2013) (prejudice standard on evidentiary rulings)
- Hadley v. State, 357 S.W.3d 267 (Mo. Ct. App. 2012) (test for reversible prejudice vs. harmless error)
- Crews v. State, 406 S.W.3d 91 (Mo. Ct. App. 2013) (bench-trial presumption that judge disregards inadmissible evidence)