State v. Mauchenheimer
342 S.W.3d 894
Mo. Ct. App.2011Background
- Detective Anderson, undercover in Yahoo chat, posed as 14-year-old 'sadmogirl' and communicated with Mauchenheimer ('abcglen').
- Mauchenheimer exposed himself via webcam on Oct 17, 2008 and made sexual comments in subsequent chats.
- Yahoo records linked 'abcglen' to Mauchenheimer; computer seized with chats archived, though some transcripts were deleted.
- Mauchenheimer was charged on Feb 9, 2009 with attempted sexual misconduct involving a child by indecent exposure.
- Mauchenheimer moved for discovery March 25, 2010 seeking Detective Anderson's hard drive; pretrial court denied discovery.
- Trial April 7, 2010: Mauchenheimer admitted chats and exposure; convicted and sentenced to four years; appeal followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether denial of discovery was an abuse of discretion | Mauchenheimer argues Brady applies; rights to exculpatory material. | State asserts Rule 25.04, no fundamental unfairness; Brady not controlling. | No abuse; no fundamental unfairness; Brady inapplicable. |
Key Cases Cited
- State v. Tisius, 92 S.W.3d 751 (Mo. banc 2002) (abuse-of-discretion standard for discovery orders)
- State v. Holden, 278 S.W.3d 674 (Mo. banc 2009) (Brady not applicable to pre-trial discovery contrary to trial record)
- State v. Trenter, 85 S.W.3d 662 (Mo. App. W.D.2002) (trial court credibility in evidentiary matters)
- State v. Stewart, 18 S.W.3d 75 (Mo. App. E.D.2000) (disclosure limits when not in state possession)
- State v. Middlemist, 319 S.W.3d 531 (Mo. App. S.D.2010) (favorable material and material to guilt/punishment)