STATE OF MISSOURI, Plaintiff-Respondent v. MITCHELL BRUMFIELD

CourtMissouri Court of Appeals
DecidedJuly 28, 2023
DocketSD37173
StatusPublished

This text of STATE OF MISSOURI, Plaintiff-Respondent v. MITCHELL BRUMFIELD (STATE OF MISSOURI, Plaintiff-Respondent v. MITCHELL BRUMFIELD) 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. MITCHELL BRUMFIELD, (Mo. Ct. App. 2023).

Opinion

Missouri Court of Appeals Southern District

In Division STATE OF MISSOURI, ) ) Plaintiff-Respondent, ) ) v. ) No. SD37173 ) Filed: July 28, 2023 MITCHELL BRUMFIELD, ) ) Defendant-Appellant. )

APPEAL FROM THE CIRCUIT COURT OF MISSISSIPPI COUNTY

Honorable R. Zac Horack, Special Judge

AFFIRMED

Mitchell Brumfield (Defendant) appeals from his convictions for abuse or neglect of

a child and second-degree murder. See § 568.060; § 565.021. 1 Defendant presents two

points on appeal. He contends the trial court abused its discretion by: (1) admitting autopsy

photographs of the victim as evidence; and (2) permitting a prosecution witness to use a doll

to demonstrate his testimony. Because we find both points to be without merit, we affirm.

Factual and Procedural Background

On March 29, 2018, police officers in Charleston, Missouri, responded to a call that

an eight-month-old infant (Victim) was “not breathing” and “unresponsive.” When police

1 All statutory references are to RSMo (2016), unless otherwise specified. arrived at the home owned by Victim’s mother, they found Defendant holding Victim in his

arms. Victim was transported to a hospital where she died the next day.

Defendant was charged with abuse or neglect of a child and second-degree murder.

A jury trial was held beginning on April 28, 2021.

The prosecutor called Dr. Russell Deidiker as a medical expert witness. He had

performed the autopsy of Victim and testified regarding the results of that autopsy. He

explained the nature of Victim’s injuries, which included significant damage to the brain and

problems with several other organs that resulted from the brain injury. Dr. Deidiker

described what actions could and could not have caused the injuries to Victim. During Dr.

Deidiker’s testimony, the prosecutor sought to admit seven photographs of the exterior of

Victim’s body taken during the autopsy. Over defense counsel’s objection, the trial court

admitted the photographs.

The prosecutor also presented testimony from police officer Matt Lindenmeyer

(Officer Lindenmeyer). He had been an officer for approximately 20 years. He was the

Investigations Manager for the Missouri State Technical Assistance Team (STAT). This

agency, with the powers of arrest, provides law enforcement officers with “technical

investigative assistance to multi-disciplinary team regencies across the State of Missouri.”

STAT also provides training and best practices for child abuse investigation throughout

Missouri. Officer Lindenmeyer had received over 1,000 hours in specific law enforcement

training, most of which specialized in child abuse investigations. He had investigated

hundreds of incidents, at least 12 of which involved the death of a child.

Officer Lindenmeyer was asked to investigate this case by the Charleston

Department of Public Safety. The officer spoke with Dr. Deidiker and read the autopsy

report. He conducted one interview with Victim’s mother and two interviews with

2 Defendant. During Officer Lindenmeyer’s testimony, he described these interviews to the

jury.

The prosecutor then asked Officer Lindenmeyer, based on his education and

experience, whether he knew what types of movements would cause the injuries that Victim

had suffered. Defense counsel objected on the ground that Officer Lindenmeyer was not a

doctor. At the trial court’s request, the prosecutor laid the following additional foundation

for such testimony:

Q. Sir, can you give us a brief synopsis of your education in investigating traumatic brain injuries in children?

A. Sure. I’ve been through the medical-legal death investigation school for specifically abusive head trauma, and toddler infant deaths. I’m actually an instructor for the Missouri [STAT] for best practices for child death investigation. I also instruct for the Missouri State Highway Patrol, the Missouri Office of Prosecution Services, Missouri Kids First, and a multitude of other agencies regarding abusive head trauma cases.

Q. Okay. And in your training to be an instructor and giving instructions on this, you have achieve[d] relative knowledge as to what types of things would cause traumatic brain injuries in children?

A. Yes, sir. You do not have to be a medical doctor to understand abusive head trauma and how it occurs.

Q. And approximately how many seminars have you conducted on it?

A. I’ve taught at global, State and national levels regarding the child abuse topic.

After this testimony was adduced, the trial court overruled the objection. Officer

Lindenmeyer then explained how a baby’s brain can be injured as the result of a shaking

mechanism called a “coup-contrecoup.” Using a doll, he demonstrated what actions could

cause a coup-contrecoup injury. The entirety of the demonstration is recorded on 2/3 of one

page of the transcript. During cross-examination, defense counsel did not ask any questions

about the demonstration.

3 The jury found Defendant guilty on both counts. Defendant was sentenced to 15

years on Count 1 and life imprisonment on Count 2. The trial court ordered the sentences to

be served consecutively. This appeal followed.

Standard of Review

Both of Defendant’s points on appeal challenge the admission of evidence by the

trial court, which we review for an abuse of discretion. State v. Brandolese, 601 S.W.3d

519, 533 (Mo. banc 2020). A trial court abuses its discretion with respect to the admission

of evidence only when the ruling is:

clearly against the logic and circumstances then before the court and is so arbitrary and unreasonable as to shock the sense of justice and indicate a lack of careful consideration; if reasonable persons can differ about the propriety of the action taken by the trial court, then it cannot be said that the trial court abused its discretion.

State v. Brown, 939 S.W.2d 882, 883-84 (Mo. banc 1997); Brandolese, 601 S.W.3d at 533.

Additionally, we review the trial court’s ruling for prejudice, not mere error, and we will

reverse only if the error was so prejudicial that it deprived the defendant of a fair trial.

Brandolese, 601 S.W.3d at 533-34.

Discussion and Decision

Point 1

Defendant contends the trial court abused its discretion by admitting the autopsy

photographs of Victim. He argues that the photographs were not legally relevant because

they “served no discernible useful, evidentiary purpose” and were “needlessly

inflammatory.”

The Supreme Court of Missouri explained the standards for the admission of

photographs as follows:

4 The trial court is vested with broad discretion in the admission of photographs. Photographs are relevant if they show the scene of the crime, the identity of the victim, the nature and extent of the wounds, the cause of death, the condition and location of the body, or otherwise constitute proof of an element of the crime or assist the jury in understanding the testimony. A photograph is not rendered inadmissible simply because other evidence described what is shown in the photograph. If a photograph is relevant, it should not be excluded simply because it may be inflammatory. As with other relevant evidence, a photograph should not be excluded from evidence unless its prejudicial effect is greater than its probative value. Insofar as photographs tend to be shocking or gruesome, it is almost always because the crime is shocking or gruesome.

State v.

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STATE OF MISSOURI, Plaintiff-Respondent v. MITCHELL BRUMFIELD, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-missouri-plaintiff-respondent-v-mitchell-brumfield-moctapp-2023.