State v. Sigmon, 517 S.W.3d 653

Sigmon was arrested after an intoxicated, aggressive confrontation during which he physically approached and assaulted Officer Travis Stafford and threatened officers; he was handcuffed and transported to jail.
During the encounter and transport, Sigmon made multiple verbal threats including statements to kill Officer Stafford and sexual/kidnapping threats regarding Officer Stafford’s young blonde daughter.
At booking, Sigmon became belligerent, damaged a padded cell with a ring, lunged at corrections staff, and was tased; he testified to heavy intoxication and limited memory of events.
A jury convicted Sigmon of multiple assaults, aggravated stalking (against Officer Stafford), and second-degree sexual misconduct (regarding the daughter); he was acquitted of escape.
On appeal Sigmon challenged sufficiency of the evidence for aggravated stalking (course-of-conduct element) and for sexual misconduct (whether he solicited sexual conduct).
The court affirmed the assault convictions but reversed and vacated the aggravated-stalking and sexual-misconduct convictions and corresponding sentences.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Sigmon)	Held
Sufficiency for aggravated stalking—was there a "course of conduct" (two or more acts evidencing continuity)?	Multiple threats during arrest and transport were separable acts showing a continuity of purpose and thus satisfy course-of-conduct.	All threats arose during one continuous confrontation and immediate aftermath; multiple utterances in a single encounter do not constitute separate acts for stalking.	Reversed: threats occurred in one continuous episode without meaningful separation in time/space, so no lawful "course of conduct."
Sufficiency for second-degree sexual misconduct—did defendant "solicit or request" sexual conduct with the officer’s daughter?	The sexualized threats toward the daughter demonstrated solicitation or could be inferred from context.	Comments were threatening, not solicitations or requests; no petitioning or attempt to obtain consent was shown.	Reversed: threats were violent/coercive, not solicitations; no evidence defendant requested sexual conduct.

State v. Hosier, 454 S.W.3d 883 (Mo. banc 2015) (standard for sufficiency review)
State v. Lammers, 479 S.W.3d 624 (Mo. banc 2016) (evidence viewed in light most favorable to verdict)
State v. Mabry, 285 S.W.3d 780 (Mo. App. E.D. 2009) (single-instance yelling during one encounter insufficient for stalking)
State v. Bernhardt, 338 S.W.3d 830 (Mo. App. E.D. 2011) (repeated separate appearances with weapon supported stalking)
M.S. v. N.M., 485 S.W.3d 792 (Mo. App. E.D. 2016) (multiple threats in one phone call are one incident, not multiple acts)
M.L.G. v. R.W., 406 S.W.3d 115 (Mo. App. E.D. 2013) (single violent altercation cannot be split into multiple incidents for stalking)
State v. Moore, 90 S.W.3d 64 (Mo. banc 2002) (definition of solicitation for sexual-misconduct statute)
State v. Sears, 298 S.W.3d 561 (Mo. App. E.D. 2009) (solicit defined as to petition or urge; solicitation may be inferred from circumstances)