State v. Jones, 427 S.W.3d 191

Jones challenged convictions for second-degree murder, first-degree endangering the welfare of a child, and second-degree assault on sufficiency grounds and plain-error review of admitted statements.
S.J. died by suffocation; D.W. malnourished with ensuing hospitalizations; doctors and social workers advised safe sleeping and feeding practices.
Ms. Jones made out-of-court statements to police that were later used as substantive evidence for murder; the death certificate was amended after review.
Hospital staff educated Jones on safe infant care; Jones ultimately admitted to leaving S.J. uncovered and on a pillow, and she took D.W. home against medical advice.
The trial court admitted the statements; the court of appeals transferred to the Missouri Supreme Court; the Supreme Court upheld the convictions.
The Supreme Court affirmatively held that corpus delicti was proven and the evidence sufficed to support all three convictions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Corpus delicti plain error review	Jones asserts admission without corpus delicti corroboration	Jones contends error obvious and injustice occurred	Plain error not established; corroborating evidence existed
Second-degree murder sufficiency	Jones argues no knowledge that death was practically certain	State shows knowledge via circumstantial evidence and statements	Sufficient evidence to support knowing murder conviction
First-degree endangering welfare sufficiency	Jones claims insufficient proof of knowing risk	State shows practical certainty of risk from under-feeding and removal from hospital	Sufficient evidence to support endangering conviction
Second-degree assault sufficiency	Jones argues no recklessness; distracted by TV	State proves conscious disregard of risk to infant	Sufficient evidence to support assault conviction

State v. Letica, 356 S.W.3d 157 (Mo. banc 2011) (plain-error review when warranted; corpus delicti standard)
State v. Baumruk, 280 S.W.3d 600 (Mo. banc 2009) (plain-error review; facially substantial grounds required)
State v. Brown, 902 S.W.2d 278 (Mo. banc 1995) (plain-error review limitations)
State v. Edwards, 116 S.W.3d 511 (Mo. banc 2008) (corpus delicti requires some corroboration)
State v. Madorie, 156 S.W.3d 351 (Mo. banc 2005) (corpus delicti corroboration sufficiency where independent evidence tends to prove)
State v. Summers, 362 S.W.2d 537 (Mo.1962) (uncorroborated statements insufficient to sustain conviction)
State v. Rodden, 728 S.W.2d 212 (Mo. banc 1987) (consciousness of guilt evidence; admissibility considerations)
State v. Davis, 407 S.W.3d 721 (Mo.App.2013) (knowledge for endangerment; practical certainty standard)
State v. Miller, 372 S.W.3d 455 (Mo. banc 2012) (standard for reviewing sufficiency of evidence)