State v. Jamison
2012 Mo. App. LEXIS 606
Mo. Ct. App.2012Background
- Jamison was charged with multiple robberies and confronted a motion to dismiss under the Interstate Agreement on Detainers (IAD).
- Ms. Collins identified Jamison as the robber at the gas station with 100% certainty in live lineups; Ms. Mayo could not identify anyone.
- Jamison moved to dismiss for failure to prosecute under the IAD; the trial court denied the motion.
- At trial, a complaining witness testified that prior robberies helped her focus on suspect details, over Jamison's objection.
- The IAD analysis centered on 180-day disposition requirements, written requests, and when protections terminated; the court analyzed Sackman to determine custody and discharge implications.
- The conviction included two counts of first-degree robbery, one count of attempted robbery, and three counts of armed criminal action, with a total of 20 years' imprisonment; the appeal challenged IAD, juror, and witness-credibility issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the IAD dismissal was proper | Jamison argues IAD 180-day deadline was triggered | State contends no valid court receipt and discharge ended protections | No error; protections expired before trial; no proper 180-day trigger |
| Whether the trial court erred in denying the strike for cause | Jamison challenges venireman suitability | Gennaro did not serve on the jury, so admissibility of the challenge is moot | No reversible error; juror did not participate in verdict |
| Whether the witness testimony about prior robberies was admissible | Testimony was improper bolstering and irrelevant to identification | Background details relevant to credibility and recollection are admissible | Admissible; proper foundation for credibility and recollection |
Key Cases Cited
- Sackman v. State, 277 S.W.3d 304 (Mo.App. E.D. 2009) (IAD protections end when custody in another state ends; 180-day rule requires receipt by court and prosecutor)
- State v. Vinson, 182 S.W.3d 709 (Mo.App. E.D. 2006) (de novo review of IAD issues; factual weight to trial court findings)
- State v. Garvey, 328 S.W.3d 408 (Mo.App. E.D. 2010) (juror qualification review subject to abuse-of-discretion standard)
- State v. Gaines, 316 S.W.3d 440 (Mo.App. W.D. 2010) (voir dire and prognosis of juror impact; preservation limits)
- Wilcox v. Coons, 241 S.W.2d 907 (Mo. banc 1951) (witness credibility and background information may be probative)