State of Missouri v. Christopher B. Buechting

CourtMissouri Court of Appeals
DecidedJuly 27, 2021
DocketED108511
StatusPublished

This text of State of Missouri v. Christopher B. Buechting (State of Missouri v. Christopher B. Buechting) 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. Christopher B. Buechting, (Mo. Ct. App. 2021).

Opinion

In the Missouri Court of Appeals Eastern District DIVISION TWO

STATE OF MISSOURI, ) ED108511 ) Respondent, ) Appeal from the Circuit Court ) of Jefferson County ) 17JE-CR00250-01 v. ) ) Honorable Victor J. Melenbrink CHRISTOPHER B. BUECHTING, ) ) Filed: July 27, 2021 Appellant. )

Christopher B. Buechting (Appellant) appeals from the trial court’s judgment, following

a jury trial, convicting him of second-degree murder, in violation of Section 565.021, RSMo

2016. 1 He was sentenced to twenty-eight years in the Missouri Department of Corrections. We

affirm.

BACKGROUND

In September 2019, Appellant was convicted of murder in the second degree for causing

the death of Angela McDonald (Victim). He now appeals, challenging the testimony of Victim’s

friends, Robyn (Robyn) and Brittany (Brittany) Walsh, 2 William Borden (Borden), and Victim’s

daughter, Summer McDonald (Daughter). Prior to trial, Appellant filed a motion in limine

1 Unless otherwise indicated, all statutory citations are to the RSMo. (2016). 2 Robyn is Brittany’s mother. To avoid confusion, they are referred to by their first names. No familiarity or disrespect is intended. arguing the statements were inadmissible as unreliable hearsay or propensity/character evidence

of prior bad acts or uncharged crimes. The State filed a response to Appellant’s motion,

asserting the evidence of prior domestic abuse was directly relevant to show Appellant’s hostility

toward Victim and motive to injure her. The State also claimed the hearsay statements were

admissible pursuant to the forfeiture by wrongdoing doctrine set forth in Giles v. California, 554

U.S. 353 (2008), and State v. McLaughlin, 265 S.W.3d 257 (Mo. banc 2008). In an August 28,

2019 written order, the trial court granted Appellant’s motion as to Borden, Robyn, and Brittany,

and in part, as to Daughter. However, the court deferred a final determination until the issues

arose at trial, especially in regard to the admissibility of evidence pursuant to the forfeiture by

wrongdoing doctrine.

At trial and relevant to this appeal, the court held a hearing outside the presence of the

jury after selection but before the jurors were sworn. First, the court accepted the parties’

stipulation that Appellant was a prior felony offender and a persistent misdemeanor offender. 3

Then the court heard arguments on the “legally controversial evidence that the State anticipate[d]

presenting” and Appellant’s motion in limine. The trial court noted it did not have much

procedural guidance and rejected Appellant’s argument that a finding should be made regarding

evidence admitted pursuant to the forfeiture by wrongdoing doctrine. 4 The court ultimately

3 In addition to the convictions set forth in this stipulation, there was a pending misdemeanor charge for third-degree assault against Victim in September 2015. Indeed, the State never raised this charge to support the doctrine of forfeiture by wrongdoing at any time during the trial. However, the record reveals it was raised at the bond reduction hearing. We take judicial notice of our own court records in this matter, which a court may do, especially where ascertainment of the truth is of paramount importance or where necessary for the court to engage in a reasonable exercise of its discretion. Knorp v. Thompson, 175 S.W.2d 889, 894 (Mo. 1943). 4 Specifically, the trial court remarked, “For better or worse, I don’t have a whole lot of procedural guidelines from higher authority on how exactly this is supposed to work.” However, in 2021, the Missouri Legislature provided just such guidance by codifying the forfeiture by wrongdoing doctrine into law. The statute provides that an otherwise inadmissible statement by a witness is admissible as substantive evidence in a criminal proceeding when the court finds by a preponderance of evidence that the defendant engaged in or acquiesced to wrongdoing with the purpose of causing the unavailability of the witness; the wrongdoing in which the defendant engaged in or acquiesced to has caused or substantially contributed to the unavailability of the witness; the state exercised due

2 concluded the Victim’s interaction with law enforcement the day before her death, as detailed

herein, was sufficient to invoke Giles and McLaughlin and allowed the State to present the

testimony pursuant to the forfeiture by wrongdoing doctrine. The trial court also indicated it

would rule upon each statement regarding Appellant’s prior bad acts as it was being introduced,

but opined the defense’s evidence of self-harm could open the door to the State’s evidence of

past incidents to provide context.

In the light most favorable to the verdict, the following evidence was adduced at trial.

Appellant and Victim moved into a trailer together sometime in September 2015. On January

22, 2017, Appellant left the trailer and placed a 9-1-1 call around 4 p.m. He stated it was not an

emergency, but he did not want to be at the trailer if Victim was there because she was jealous

and angry with him. He claimed she threw a brick or rock at him, and purposely hit her head on

the door as he drove away. He adamantly denied the need to meet with authorities to make a

report, even at a different location.

Jefferson County Sheriff Deputy Andrew Godi (Deputy Godi) responded to Appellant’s

9-1-1 call. When Victim answered the door, Deputy Godi observed she had a dark bruise under

her left chin and bruising under her left eye. She was also holding her left side and complained

of rib pain. Victim told Deputy Godi she had an argument with Appellant earlier that day. She

refused to go to the hospital either with Deputy Godi or by ambulance. However, she did allow

him to contact a women’s shelter to see if she could spend the night, but changed her mind. She

then allowed Deputy Godi to call her friends, Brittany and Robyn, who arrived soon thereafter.

They also noticed Victim’s black eye and bruised chin. Deputy Godi left after Victim agreed to

go home with them. However, Victim again changed her mind and remained at the trailer.

diligence to secure the attendance of the witness, or the witness is unavailable because the defendant caused the death of the witness; and the witness fails to appear at the proceeding. Section 491.016 (emphasis added).

3 Brittany testified Victim was scared and Robyn observed that she could not stand up straight.

Victim explained to her friends that Appellant had punched her in the ribs several times and that

she thought they were broken. Appellant objected to this testimony as hearsay, but the State

argued it was admissible pursuant to prior motion arguments. 5 The objection was overruled by

the trial court.

Brittany also testified that at Victim’s request, she had spent 15 to 20 minutes with her at

the trailer earlier that day after Appellant left but before Deputy Godi arrived. Over Appellant’s

continuing hearsay objection, she stated that Victim was upset with her and told her that if she

“would have showed up earlier, none of this would have happened.” Brittany had noticed – but

did not ask about – Victim’s black eye and bruised chin. She inferred that Victim was talking

about her injuries.

Appellant testified that when he returned later in the day, he physically removed Victim

from the trailer with his left arm and locked her out. Appellant allowed her back inside after she

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Related

Reynolds v. United States
98 U.S. 145 (Supreme Court, 1879)
Crawford v. Washington
541 U.S. 36 (Supreme Court, 2004)
Giles v. California
554 U.S. 353 (Supreme Court, 2008)
State v. McLaughlin
265 S.W.3d 257 (Supreme Court of Missouri, 2008)
State v. Tolliver
101 S.W.3d 313 (Missouri Court of Appeals, 2003)
State v. Ponder
950 S.W.2d 900 (Missouri Court of Appeals, 1997)
State v. Burns
978 S.W.2d 759 (Supreme Court of Missouri, 1998)
State v. Wolfe
13 S.W.3d 248 (Supreme Court of Missouri, 2000)
State v. Justus
205 S.W.3d 872 (Supreme Court of Missouri, 2006)
State v. Middlemist
319 S.W.3d 531 (Missouri Court of Appeals, 2010)
State v. March
216 S.W.3d 663 (Supreme Court of Missouri, 2007)
State v. Fassero
256 S.W.3d 109 (Supreme Court of Missouri, 2008)
State v. Ellison
239 S.W.3d 603 (Supreme Court of Missouri, 2007)
State v. Sutherland
939 S.W.2d 373 (Supreme Court of Missouri, 1997)
State v. Williams
673 S.W.2d 32 (Supreme Court of Missouri, 1984)
State v. Moore
352 S.W.3d 392 (Missouri Court of Appeals, 2011)
LAS PALMAS MEDICAL CENTER v. Moore
349 S.W.3d 57 (Court of Appeals of Texas, 2010)
State v. Floyd
347 S.W.3d 115 (Missouri Court of Appeals, 2011)
State of Missouri v. David Russell Hosier
454 S.W.3d 883 (Supreme Court of Missouri, 2015)
Knorp v. Thompson
175 S.W.2d 889 (Supreme Court of Missouri, 1943)

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State of Missouri v. Christopher B. Buechting, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-missouri-v-christopher-b-buechting-moctapp-2021.