State v. Rasheed, 340 S.W.3d 280

Rasheed was charged in state court as a prior/persistent offender with trafficking cocaine base (crack) in the second degree and possession of ecstasy.
Before the state trial, Rasheed pled guilty in federal court to possession with intent to distribute controlled substances stemming from the same facts.
Rasheed moved to suppress both seized drugs and his custodial confession; the suppression motion was granted in part and denied in part, with confession suppression denied.
At trial, the State read excerpts from Rasheed's federal plea into the record; Rasheed was convicted on both counts and sentenced to 10 years on each count, to be served concurrently with each other and the federal sentence.
Rasheed appealed, challenging admissibility of the federal plea, a closing-argument remark, and suppression rulings.
The appellate court affirmed, addressing the admissibility of the plea, plain-error review for closing arguments, and suppression standards.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of federal plea	Rasheed contends the federal plea was involuntary and improperly admitted.	Rasheed argues his counsel failed to inform of potential state-use of the plea.	Trial court did not abuse discretion; plea admissible as collateral consequence; evidence of federal plea properly admitted.
Closing argument plain error	State's closing remark improperly denigrated Rasheed using the federal plea admission.	Rasheed asserts the remark violated limits on closing and inflamed jurors.	No plain error; remark supported by record and did not have decisive effect on the verdict.
Suppression of statements and evidence	Tip lacked reasonable suspicion to justify stop; evidence should be suppressed as fruits.	Stop was based on reliable informant tip corroborated by police; search valid.	No plain error; tip sufficiently corroborated; stop valid under Terry framework; suppression not warranted.

State v. Dennis, 315 S.W.3d 767 (Mo.App. E.D.2010) (abuse-of-discretion standard for evidentiary rulings)
State v. Hadley, 249 S.W.2d 857 (Mo.1952) (guilty plea admissibility as admission of truth)
United States v. Holmes, 794 F.2d 345 (8th Cir.1986) (guilty plea admissible as admission by party opponent)
United States v. Williams, 104 F.3d 213 (8th Cir.1997) (collateral consequence analysis of state plea in subsequent federal case)
State v. Long, 22 S.W.2d 809 (Mo.1939) (direct vs. collateral consequences of a guilty plea)
Reynolds v. State, 994 S.W.2d 944 (Mo. banc 1999) (direct consequences of a guilty plea standard)
Banks, 215 S.W.3d 118 (Mo. banc 2007) (closing-argument boundaries and ad hominem limits)
White, 247 S.W.3d 563 (Mo.App. E.D.2007) (standard for determining plain-error in closing argument)
Clemons, 946 S.W.2d 206 (Mo. banc 1997) (permitted inferences based on evidence in closing arguments)
Deck, 994 S.W.2d 527 (Mo. banc 1999) (reasonable-suspicion standard for police stops)
Alabama v. White, 496 U.S. 325 (1990) (tip-based reasonable suspicion framework for Terry stops)