State v. Wiley
337 S.W.3d 41
| Mo. Ct. App. | 2011Background
- Wiley stabbed and seriously injured an acquaintance, Hatley, after a beer-sharing encounter on Wiley’s porch; Hatley, unarmed and with no dispute, was stabbed and later life-flighted to a Memphis hospital.
- Wiley, who admitted three prior felonies (two for felony assault), was tried as a persistent offender and claimed self-defense.
- Hatley described events vaguely; Wiley testified Hatley staggered and insulted him, and that he acted in self-defense when Hatley punched him.
- The knife used in the stabbing was recovered with blood on it; Wiley attempted to hide it by giving it to a neighbor, who alerted police.
- The jury convicted Wiley of first-degree assault and armed criminal action; Wiley appeals on evidentiary and Batson-related issues, among others, and the appellate court affirms.
- The court discusses whether exclusion of Hatley’s statement about intending to kill a racial slur affected the self-defense instruction and whether Batson concerns invalidated the strike of an African-American venireperson.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether exclusion of Hatley’s statement prejudiced self-defense. | Wiley argues the statement showed Hatley’s aggressor status. | Hatley’s statement would help the defense on initial aggressor theory. | No reversible error; no substantial evidence supported self-defense instruction. |
| Whether the State’s Batson strike of S.R. was racially motivated. | Wiley contends the strike was race-based. | State gave race-neutral, non-pretextual reasons. | Not clearly erroneous; Batson challenge denied. |
Key Cases Cited
- State v. Wilkins, 229 S.W.3d 204 (Mo.App.2007) (prejudice standard for evidentiary rulings; abuse of discretion review)
- State v. Bell, 950 S.W.2d 482 (Mo.banc 1997) (declarant’s present mental state may be admissible in limited self-defense context)
- State v. Burks, 237 S.W.3d 225 (Mo.App. 2007) (deadly force rules; castle doctrine exceptions; four prerequisites to deadly force in self-defense)
- State v. Dorsey, 113 S.W.3d 311 (Mo.App. 2003) (insults not provocation; deadly force requires immediate danger and real necessity)
- Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (prohibition on race-based peremptory strikes; requires race-neutral justification)
- State v. Koenig, 115 S.W.3d 408 (Mo.App. 2003) (reversal standard for Batson findings; burden on defendant to show pretext)
- Purkett v. Elem, 514 U.S. 765 (U.S. 1995) (burden-shifting framework for Batson challenges)