State v. Winfrey, 337 S.W.3d 1

Eric Winfrey was convicted by a jury of first-degree murder and first-degree robbery, sentenced as a prior offender to consecutive life terms without parole for murder and life for robbery.
The State’s case relied largely on circumstantial evidence and testimony from an informant; Winfrey claimed lack of involvement and contested the credibility of witnesses.
Key disputed issue at trial was whether Winfrey could cross-examine a witness, Mr. Lewis, about whether Lewis told a third party that he shot the victim.
Lewis testified about obtaining a gun for Winfrey and later claimed he shot the victim, a statement relevant to his credibility if admitted for impeachment.
The trial court refused to allow cross-examination on Lewis’s out-of-court statement, restricting defense impeachment unless it proved the truth of the matter asserted.
The Missouri Supreme Court held the trial court erred by excluding the cross-examination, reversing the conviction and remanding for a new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Cross-examination of a key witness for impeachment	Winfrey argues Lewis's admission to Reynolds is admissible to impeach credibility.	State contends it is hearsay and improper impeachment	Trial court erred; cross-examination allowed for non-hearsay impeachment purpose.
Admission of prison-conduct violations to impeach Covington	Covington's lies to prison staff are probative of truthfulness and credibility.	Violations were not shown with sufficient specifics; not probative of truthfulness.	Trial court did not abuse discretion; evidence excluded remains non-probative as framed.
Admission of other crimes and bad acts evidence	Other acts show motive, intent, absence of mistake, or identity; probative value outweighs prejudice.	Prejudicial and lacks proper relevance to charged offenses; admissibility limited.	Court upheld many exclusions; admissibility limited to proper purposes and outweighed by prejudice.

State v. Sutherland, 939 S.W.2d 373 (Mo. banc 1997) (hearsay and non-hearsay uses of out-of-court statements)
State v. Foster, 349 S.W.2d 922 (Mo. 1961) (impeachment of witnesses to attack credibility)
Mitchell v. Kardesch, 313 S.W.3d 667 (Mo. banc 2010) (limits on cross-examination for bias or interest; probative value vs. prejudice)
State v. Pigques, 310 S.W.2d 942 (Mo. 1958) (witness interest in testimony as impeachment motive)
State v. Fassero, 256 S.W.3d 109 (Mo. banc 2008) (principles on admissibility of prior bad acts)
State v. Mayes, 63 S.W.3d 615 (Mo. banc 2001) (motive and other-acts evidence; balancing probative value against prejudice)