STATE OF MISSOURI, Plaintiff-Respondent v. JEREMY WAYNE FLOYD

CourtMissouri Court of Appeals
DecidedDecember 20, 2019
DocketSD35686
StatusPublished

This text of STATE OF MISSOURI, Plaintiff-Respondent v. JEREMY WAYNE FLOYD (STATE OF MISSOURI, Plaintiff-Respondent v. JEREMY WAYNE FLOYD) is published on Counsel Stack Legal Research, covering Missouri Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
STATE OF MISSOURI, Plaintiff-Respondent v. JEREMY WAYNE FLOYD, (Mo. Ct. App. 2019).

Opinion

STATE OF MISSOURI, ) ) Plaintiff-Respondent, ) ) v. ) No. SD35686 ) JEREMY WAYNE FLOYD, ) Filed: December 20, 2019 ) Defendant-Appellant. )

APPEAL FROM THE CIRCUIT COURT OF SCOTT COUNTY

Honorable David A. Dolan

AFFIRMED

Jeremy Wayne Floyd (“Defendant”) appeals his convictions for one count of

possession of a controlled substance and one count of tampering with physical evidence.1

See sections 195.202 and 575.100.2 Defendant’s two points on appeal claim the trial court

abused its discretion in excluding proffered hearsay testimony from a witness who claimed

that another person told her that the drugs at issue belonged to him, not to Defendant.

Finding no merit in that claim, we affirm.

Standard of Review

“We review the trial court’s decision to admit or exclude evidence for an abuse of discretion.” State v. Hudson, 230 S.W.3d 665, 669 (Mo.App. 2007).

1 While Defendant’s points purport to challenge both of his convictions, his argument addresses only his conviction for possession of a controlled substance, and we will limit our analysis accordingly. Defendant was sentenced to serve a total of 15 years in the Department of Corrections. 2 Unless otherwise indicated, all statutory citations are to RSMo 2016.

1 “The trial court is vested with broad discretion in ruling on questions of admissibility of evidence, and, absent a clear showing of abuse of discretion, this Court should not interfere with the trial court’s ruling.” State v. Avery, 275 S.W.3d 231, 235 (Mo. banc 2009). Moreover, our review “is for prejudice, not mere error, and the trial court’s decision will be reversed only if the error was so prejudicial that it deprived the defendant of a fair trial.” State v. Johnson, 207 S.W.3d 24, 34 (Mo. banc 2006).

State v. Buller, 582 S.W.3d 124, 128 (Mo. App. S.D. 2019).

The Evidence

Sikeston police officers executed a search warrant at a residence during the early

morning hours. They found eight or ten people inside. Those present included Defendant,

Defendant’s brother, April Shivers (“Ms. Shivers”), and Dakota “Cody” Smith (“Cody”).

Ms. Shivers was the girlfriend of Defendant’s brother. When the officers approached the

house, Defendant was standing at the back door, and they told him to put up his hands.

Instead of doing so, Defendant shut and locked the door, and officers had to use a battering

ram to enter the home.

Once inside, police found Defendant walking out of a bathroom next to the living

room. No other suspects were in that particular area. In the bathroom Defendant had just

exited, officers found a running toilet that contained liquid laundry detergent and a torn

plastic bag. Inside the trap of the toilet, officers also found a large bag of methamphetamine

and a broken pipe. Defendant first told officers that he had just awakened and used the

bathroom; he later said that he had not been in the bathroom at all. Officers found digital

scales in the kitchen next to Defendant’s billfold, along with 20 to 25 corner baggies

consistent with drug distribution.

Defendant was charged with possession of a controlled substance with intent to

distribute (Count 1) and tampering with physical evidence (Count 2). On Count 1, the jury

2 found Defendant guilty of the lesser-included offense of possession of a controlled

substance. On Count 2, it found Defendant guilty as charged of tampering with physical

evidence. We will include other relevant evidence as necessary to address Defendant’s

points on appeal.

Analysis

The rejected testimony, elicited through an offer of proof from Ms. Shivers, was that

Cody later told Ms. Shivers that the drugs located by the officers were his and that

Defendant had nothing to do with them. Defendant’s points claim the trial court abused its

discretion in excluding this proffered hearsay testimony based upon two different alleged

theories of admissibility, which we will address in the order presented.

Point 1 – Admissible via Due-Process

Point 1 claims that Ms. Shivers should have been allowed to testify “about the

exculpatory out-of-court statements [Cody] made to her” because they were against Cody’s

penal interest and their exclusion deprived Defendant of his due-process right to present a

defense. Defendant first argues that the statement made by Cody to Ms. Shivers was

admissible under State v. Robinson, 90 S.W.3d 547 (Mo. App. S.D. 2002), as it was made

by an unavailable declarant, it would have totally exonerated Defendant, and it possessed

substantial indicia of reliability. In general, Missouri courts have ruled that statements

against penal interest are not a valid exception to the hearsay rule and are thus not

admissible in criminal proceedings. Id. at 551. However, such statements may be

admissible “where due process is implicated and where circumstances strongly indicate the

reliability of the statement.” Id. (citing State v. Anglin, 45 S.W.3d 470, 473 (Mo. App.

W.D. 2001)).

3 For this narrow exception to apply, a defendant must show: (1) the declarant is

unavailable as a witness; (2) there is substantial indicia of reliability of the alleged

declaration; and (3) the declaration, if true, would exonerate the defendant. Id. The

statement is admissible only if all three of these requirements are met. Id.

During her offer of proof, Ms. Shivers testified that Cody came back to the house on

the same day of Defendant’s arrest and told her that the drugs belonged to him, and that

Defendant should not go to jail when the drugs belonged to Cody. Defendant claims that

Cody’s statement “totally exonerates [Defendant] of an offense based on the possession of a

controlled substance” because “[t]here was no evidence presented at trial that [Defendant]

actually possessed the methamphetamine; the theory of guilt presented by the State was

merely that the circumstantial evidence seemed to suggest that [Defendant] had constructive

possession of it.”

This argument fails for several reasons, but we need only note that Cody’s claim of

ownership of the drugs at issue would not have exonerated Defendant because ownership is

not an element of the crime of possession of a controlled substance. Simpson v. State

Highway Patrol Criminal Records Repository, 522 S.W.3d 369, 373 (Mo. App. S.D. 2017).

The only questions for the jury to determine were whether Defendant consciously and

intentionally possessed the methamphetamine (either actually or constructively) and whether

he was aware of the methamphetamine’s presence and nature. Id. (Emphasis added.)

As Defendant concedes, the State presented substantial circumstantial evidence that

Defendant had constructive possession of the methamphetamine. He was the only person

walking out of the bathroom where the toilet was still running from just having been

flushed. The water in the toilet was blue and had bubbles on top, indicating that detergent

4 had been recently poured into the commode.3 There was a torn plastic baggie in the toilet,

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Related

State v. Hudson
230 S.W.3d 665 (Missouri Court of Appeals, 2007)
State v. Avery
275 S.W.3d 231 (Supreme Court of Missouri, 2009)
State v. Robinson
90 S.W.3d 547 (Missouri Court of Appeals, 2002)
State v. Anglin
45 S.W.3d 470 (Missouri Court of Appeals, 2001)
State v. Johnson
207 S.W.3d 24 (Supreme Court of Missouri, 2006)
State v. Shockley
410 S.W.3d 179 (Supreme Court of Missouri, 2013)
Simpson v. State Highway Patrol Criminal Records Repository
522 S.W.3d 369 (Missouri Court of Appeals, 2017)

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STATE OF MISSOURI, Plaintiff-Respondent v. JEREMY WAYNE FLOYD, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-missouri-plaintiff-respondent-v-jeremy-wayne-floyd-moctapp-2019.