State of Missouri v. Anthony Tate

CourtMissouri Court of Appeals
DecidedMay 28, 2024
DocketED111626
StatusPublished

This text of State of Missouri v. Anthony Tate (State of Missouri v. Anthony Tate) 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 v. Anthony Tate, (Mo. Ct. App. 2024).

Opinion

In the Missouri Court of Appeals Eastern District DIVISION TWO

STATE OF MISSOURI, ) No. ED111626 ) Respondent, ) Appeal from the Circuit Court ) of St. Louis County vs. ) ) Honorable Stanley J. Wallach ANTHONY TATE, ) ) Appellant. ) FILED: May 28, 2024

Introduction

Anthony Tate (“Tate”) appeals from the trial court’s judgment following jury convictions

on first-degree murder, two counts of first-degree assault, unlawful use of a weapon, unlawful

possession of a weapon, and four associated counts of armed criminal action (“ACA”) arising

out of a drive-by shooting in a parking lot. Tate raises four points on appeal. Points One and

Two assert the trial court erred in overruling Tate’s motion for acquittal on the counts of first-

degree assault against M.E. and A.H., respectively, because the State adduced insufficient

evidence that Tate caused either victim serious physical injury. Points Three and Four raise

unpreserved claims of plain error. Point Three contends the trial court plainly erred in not

intervening sua sponte when the State made an improper acquittal-first closing argument. Point

Four claims the trial court plainly erred in failing to strike sua sponte a detective’s hearsay

testimony because it went to the ultimate issue of whether Tate was involved in the shooting.

Because the State failed to present to the jury sufficient evidence from which it reasonably could find that M.E. and A.H. suffered serious physical injury, we grant Points One and Two. Because

Tate has not demonstrated manifest injustice from either allegation of plain error, we deny Points

Three and Four. Accordingly, we affirm the trial court’s judgment in part, and we reverse and

remand in part for further proceedings consistent with this opinion.

Factual and Procedural History

The following facts are limited to only those necessary to resolve the appeal and are

presented in the light favorable to the jury verdicts.1 On December 12, 2019, Tate drove a silver

Ford Edge SUV (“Ford Edge’) into a barbershop parking lot, where he waited twenty-three

minutes until he could pull beside another car parked in the lot. Then, acting either alone or with

an accomplice, Tate fired fifteen shots into the other car, killing T.S. and injuring M.E. and A.H.

After being shot, T.S., M.E., and A.H. ran to the barbershop. T.S. died at the scene after

bleeding out on the pavement from his gunshot wounds. A.H. was shot in the leg. M.E. was

shot in the left thigh and left hand. When police arrived, M.E. was standing on the sidewalk,

then he sat on the ground and allowed an officer to begin treating his gunshot wounds. A.H. had

been walking around inside the barbershop, then either lay or collapsed on the ground in the

doorway when police arrived. A.H. stood up with the help of a police officer and limped a few

steps before sitting down on the sidewalk. A police officer cut A.H.’s pants from the bottom to

expose and treat the wound, where the bullet was visibly lodged under his knee. Paramedics

arrived, placed both Victims on stretchers, and took them to the hospital by ambulance.

After the shooting, Tate drove the vehicle to a nearby gas station, where surveillance

video footage showed him wearing distinctive clothing and having a tattoo or discoloration on

his left hand. Approximately, two weeks after the shooting, Tate fled police during a traffic stop

1 See State v. Johnson, 284 S.W.3d 561, 568 (Mo. banc 2009) (internal citation omitted).

2 while he was driving the Ford Edge. Tate abandoned the vehicle and ran into the basement of a

house belonging to people he did not know. The police followed and arrested Tate, recovering a

backpack containing the gun used in the shooting as confirmed by bullet ballistics. Tate had

previously made social media posts of himself holding the gun. Tate spoke with police officers

when he was arrested. A recording of his police station interview was admitted into the record

but was not played for the jury.

The State charged Tate with first-degree murder of T.S., first-degree assault against

Victims M.E. and A.H., unlawful use of a weapon, unlawful possession of a weapon, as well as

four counts of ACA.2 At trial, the State introduced evidence of M.E. and A.H.’s injuries through

surveillance video footage of the shooting, hospital photographs of Victims’ bandaged injuries,

and the testimony of Detective D.S., who spoke with Victims in the hospital’s emergency trauma

department. Detective D.S. testified that the Victims’ injuries were consistent with the doctor’s

diagnoses of gunshot wounds. The State then moved to have Victims’ 100–150-page hospital

records admitted into evidence, which the trial court granted with no objection from the defense.

The State published to the jury only one page from each Victim’s hospital records. The one

published page for each Victim stated the diagnoses of gunshot wound, the arrival and discharge

time for each Victim, and the stable medical condition of each Victim upon discharge. In closing

argument, the State argued to the jury that it had proved Tate caused M.E. and A.H. serious

physical injury because they were shot. During deliberations, the jury did not request to review

M.E. or A.H.’s medical records.

Throughout trial, Tate’s theory of defense was misidentification. Tate testified in his

own defense and said that he did not know the Victims and did not shoot them. Tate admitted

2 The State also charged Tate with first-degree assault and ACA against a fourth victim, M.M., alleging that Tate also opened fire on M.M.’s car. The jury acquitted Tate on these charges, and they are not before us on appeal.

3 driving the Ford Edge on a later date and fleeing police officers who attempted to detain him, but

he denied driving the Ford Edge during the shooting.

Detective J.P. testified that cellphone records placed Tate near the shooting’s location.

Tate admitted it was his phone but stated it was a shared phone used for selling marijuana

illegally and he did not have it on the day of the shooting. Prior to Detective J.P. taking the

stand, the parties agreed not to elicit information about whether the State filed charges against

C.M., Tate’s cousin, whom the State also investigated. Detective J.P opined that his

investigation of C.M. implicated Tate because C.M. was an associate of Tate’s and because both

men’s cellphone records placed them near the shooting. Tate did not object to Detective J.P.’s

testimony. Tate cross-examined Detective J.P. about the investigation of C.M., eliciting that

C.M. had the same distinctive outfit Tate wore on the night of the shooting. Tate implied the

State may have misidentified him for C.M. Tate testified that C.M. was his cousin and that he

was near C.M.’s house at the time of the shooting.

In closing, the State argued to the jury that it met its burden to prove beyond a reasonable

doubt that Tate committed first-degree murder against T.S. by firing fifteen rounds into an

occupied vehicle. The State acknowledged Tate’s defense of misidentification but argued it

proved that Tate was driving the vehicle from which the shots were fired. The State further

argued that it did not have to prove that Tate pulled the trigger due to accomplice liability law.

Regarding the deliberation element, the State argued the video surveillance footage showed

twenty-three minutes of deliberation.

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State of Missouri v. Anthony Tate, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-missouri-v-anthony-tate-moctapp-2024.