State v. Watson, 407 S.W.3d 180

Victim is Defendant’s daughter who lived with him and Mother in Imperial, Missouri.
Victim began traumatic sexual abuse by Defendant starting around age 12, including dildo use and coerced oral sex, occurring multiple times monthly.
Victim began intercourse with Defendant around age 13, often in bedroom or living room with porn playing, three to four times per month.
Mother learned of abuse later; Victim described “sex between the three of us” after Mother became involved.
Half-brother (Defendant’s son) Joseph witnessed acts and participated in “family sex sessions”; he later moved out after violent incident.
Victim disclosed abuse in 2010 to aunt and boyfriend; police consulted but initially did not pursue DNA testing due to time elapsed.
Jury found Defendant guilty on all counts (first/second degree statutory rape, two counts of first-degree sodomy, incest); trial court sentenced to 19 years.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Unanimity requirement for first-degree statutory rape	Celis-Garcia requires either electing an act or listing distinct acts.	Instruction 9 failed Celis-Garcia, confusing jurors and allowing non-unanimous verdicts.	Instruction 9 did not mislead; affirmed admission of Celis-Garcia-based directive.
Plain error in closing argument	Closing misstatements about burden of proof warranted sua sponte intervention.	Plain error occurred due to misstatement of burden and defense burden-shifting.	No plain error; court did not intervene.
Admission of Brother’s testimony about alleged violence	Evidence served to rebut defense theory and show coercive environment.	Uncharged-crimes evidence was prejudicial and should have been excluded.	No plain error; admission did not determine the outcome.

Celis-Garcia v. State, 344 S.W.3d 150 (Mo. banc 2011) (unanimity in multiple-acts cases; elect act or specify acts)
State v. Davis, 318 S.W.3d 618 (Mo. banc 2010) (abuse of discretion standard for verdict-directing instruction)
State v. Miner, 363 S.W.3d 145 (Mo. App. E.D. 2012) (plain-error review standards for instructions)
State v. Irby, 254 S.W.3d 181 (Mo. App. E.D. 2008) (plain-error review; de-emphasizes automatic reversal)
State v. Madison, 997 S.W.2d 16 (Mo. banc 1999) (burden-proof instruction; jury unanimity presumptions)
State v. Jackson, 155 S.W.3d 849 (Mo. App. W.D. 2005) (closing argument and interference considerations)
State v. Taylor, 831 S.W.2d 266 (Mo. App. E.D. 1992) (propriety of rebuttal in closing arguments)
State v. Bolds, 11 S.W.3d 633 (Mo. App. E.D. 1999) (admissibility of evidence when defense opens door)
Baker, 948 N.E.2d 1177 (2001) (treatise-style note on similar issues; repeated acts context)