State v. Hadley
2012 Mo. App. LEXIS 74
| Mo. Ct. App. | 2012Background
- Hadley was convicted by jury on four counts of recklessly exposing another to HIV under Mo. Rev. Stat. § 191.677; jury recommended 15 years on each count.
- Trial court sentenced Hadley to consecutive 15-year terms on Counts 1 and 2, and 15 years on Counts 3 and 4 concurrent with Counts 1 and 2, for an aggregate 30 years.
- Appeal challenges the admissibility of Exhibit 3 (medical records) and related testimony on hearsay, confrontation, and privilege grounds.
- Exhibit 3 was admitted during guilt; witnesses testified to its contents but the jury did not review the exhibit itself.
- Hadley claims Exhibit 3 contained hearsay (including statements about HIV testing and post-test counseling) and privileged communications, potentially violating confrontation and due-process rights.
- The court evaluated evidentiary rulings under abuse-of-discretion standard and reviewed for prejudice, not mere error, citing Mozee and McGowan.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admission of Exhibit 3 (hearsay). | Hadley contends Exhibit 3 and related testimony contained improper hearsay. | State argues court had broad discretion; any prejudice was lacking because facts were proven by other evidence. | No reversal; no prejudice; admission not reversible error. |
| Confrontation clause violation. | Hadley asserts confrontation rights were violated by admission of hearsay. | State contends admissions relied on Hadley’s own testimony and non-deliberated evidence; no prejudice. | No plain error; no prejudice to Hadley. |
| Privilege/confidential communications in medical records. | Exhibit 3 contained privileged communications; admission was plain error. | Even if privileged, admission did not cause manifest injustice; no plain error. | No plain error; no manifest injustice. |
| Penalty-phase admission of untested criminal conduct evidence (J.B., W.J.). | Evidence relevant to character; issues with hearsay and confrontation in penalty phase. | Hadley admitted certain acts on tape; other testimony corroborated; evidence supports sentencing. | No plain error; substantial evidence supported the sentence. |
Key Cases Cited
- State v. Mozee, 112 S.W.3d 102 (Mo.App. W.D. 2003) (trial court evidentiary rulings reviewed for prejudice, not mere error)
- State v. McGowan, 184 S.W.3d 607 (Mo.App. E.D. 2006) (abuse of discretion requires logic and reasonableness in rulings)
- State v. Yonts, 84 S.W.3d 516 (Mo.App. S.D. 2002) (improper hearsay evidence may be harmless where other evidence supports essential facts)
- State v. Roper, 136 S.W.3d 891 (Mo.App. W.D. 2004) (plain error standard for appellate review)
- State v. Fassero, 256 S.W.3d 109 (Mo. banc 2008) (preponderance standard for admissibility of uncharged conduct in penalty phase)
- State v. Cole, 71 S.W.3d 163 (Mo. banc 2002) (penalty phase evidence proper for character context)