State v. Steidley, 533 S.W.3d 762

Background

Steidley owned Everhart’s Sporting Goods, closed sales late 2010; returned Dec. 30 to turn on one heater and shut off other breakers (disabling computers and security).
On Jan. 1, 2011 a fire started in a warehouse storage corridor where paper records sat; an attached heater was running and the heater’s gas drip leg was found removed and soot-covered on nearby shelves.
ATF and state fire investigators concluded the fire was intentionally set with an ignitable liquid and open flame; they also concluded the drip leg was intentionally removed to introduce gas or create an explosive atmosphere.
Phone records and witness testimony placed Steidley at or near the store close in time to the fire; he made inconsistent statements about his whereabouts and asked a friend questions about gas/ explosions and later instructed that friend to lie.
Steidley was charged with second-degree arson; after a second jury trial he was convicted and sentenced to seven years. He appealed raising five points: insufficiency of evidence, Brady/Rule 25.03 discovery, leading questions, plain error in closing argument, and admissibility of hospital business records.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Steidley)	Held
1. Sufficiency of evidence to convict of 2nd-degree arson	Evidence showed incendiary origin (ignitable liquid, burn patterns), removed drip leg, motive, opportunity and inconsistent statements — sufficient for a jury.	Evidence was circumstantial and insufficient to prove he set the fire.	Affirmed: Evidence (circumstantial) was sufficient to support incendiary origin and that Steidley set the fire.
2. New trial for failure to disclose ATF materials (Brady / Mo. R. 25.03)	State disclosed what it had; Steidley knew of ATF interview/video and subpoenaed ATF himself; no undisclosed Brady material produced by prosecution.	State failed to obtain and produce ATF records (video of Buersmeyer with a gas can) and prejudiced the defense.	Affirmed: No Brady violation (defense knew of evidence); Steidley failed to preserve a Rule 25.03 claim and showed no prejudice warranting relief.
3. Trial court allowed leading questions by prosecution	Questions to Parsons elicited incriminating detail but were cumulative of other testimony; trial court has discretion to permit leading questions.	Leading questions to Parsons (direct and redirect) were improper and prejudicial.	Affirmed: No abuse of discretion; any leading questions were cumulative and not prejudicial.
4. Plain error for failure to sua sponte interrupt State’s closing (references to firefighters’ death risk)	Closing drew reasonable inferences from evidence about risks firefighters faced and motive (greed vs. safety).	Prosecutor’s remarks about risk of death were improper; trial court should have interrupted despite lack of objection.	Affirmed: No plain error—remarks were tied to record evidence and did not have a decisive effect on outcome.
5. Admission of hospital records via business-records affidavit (Confrontation Clause / §490.680)	Affidavit complied substantially with statutory form; records non‑testimonial business records admissible; Steidley failed to timely assert specific confrontation objection.	Affidavit failed to state mode/method of preparation and admission violated Sixth Amendment confrontation rights.	Affirmed: Affidavit sufficiently described mode/method; records were non-testimonial business records and no preserved confrontation error shown.

Key Cases Cited

State v. Hosier, 454 S.W.3d 883 (Mo. banc 2015) (standard for sufficiency review)
State v. Nash, 339 S.W.3d 500 (Mo. banc 2011) (accept evidence favorable to the State on review)
Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (prosecutor must disclose favorable, material evidence)
Melendez-Diaz v. Massachusetts, 557 U.S. 305 (U.S. 2009) (business records generally non-testimonial for Confrontation Clause)
State v. McFadden, 391 S.W.3d 408 (Mo. banc 2013) (trial court discretion on leading questions)