State of Missouri v. Eric G. Hollowell

CourtMissouri Court of Appeals
DecidedAugust 17, 2021
DocketED108941
StatusPublished

This text of State of Missouri v. Eric G. Hollowell (State of Missouri v. Eric G. Hollowell) 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. Eric G. Hollowell, (Mo. Ct. App. 2021).

Opinion

In the Missouri Court of Appeals Eastern District DIVISION THREE

STATE OF MISSOURI, ) No. ED108941 ) Respondent, ) Appeal from the Circuit Court of ) Washington County vs. ) ) Honorable Wendy W. Horn ERIC G. HOLLOWELL, ) ) Appellant. ) Filed: August 17, 2021

Introduction

Eric Hollowell (“Appellant”) appeals his convictions of fifteen counts of unlawful

possession of a firearm in violation of Mo. Rev. Stat. § 571.070.1 Appellant was sentenced to

concurrent seven-year sentences on fourteen counts and a four-year sentence for the fifteenth

count to be served consecutively, for eleven years in the Missouri Department of Corrections

(“DOC”).

Appellant raises four points on appeal. In Point I, Appellant argues the trial court erred

by overruling his motion for acquittal because the State failed to prove he possessed and

controlled the firearms. In Point II, Appellant argues the trial court abused its discretion by

admitting inadmissible hearsay testimony to establish Appellant’s control over the firearms. In

Point III, Appellant argues the trial court erred and violated his Sixth Amendment confrontation

1 All statutory references are to Mo. Rev. Stat. (2018), unless otherwise indicated. right by permitting a police officer to testify about Appellant’s wife’s testimonial hearsay

statement, establishing Appellant’s control over the firearms. In Point IV, Appellant argues his

right to be free of double jeopardy was violated because the unit of prosecution permitted by

section 571.070 is ambiguous.

Points I and II are dispositive. We reverse and need not consider Points III and IV.

Factual and Procedural Background

1. Investigation and Arrest

On December 19, 2018, Appellant was arrested in Irondale, Missouri after his wife

Beckey reported him to police for domestic violence against her.2 After Appellant’s arrest,

Beckey informed police Appellant had a prior felony conviction and kept numerous firearms in

their home, in violation of Missouri’s felon-in-possession of a firearm statute, section 571.070.

Section 571.070 provides:

1. A person commits the offense of unlawful possession of a firearm if such

person knowingly has any firearm in his or her possession and: (1) such

person has been convicted of a felony under the laws of this state, or of a

crime under the laws of any state or of the United States, which if committed

within this state would be a felony . . . .

2. Unlawful possession of a firearm is a class D felony . . . .

3. The provisions of subdivision (1) of subsection 1 of this section shall not

apply to the possession of an antique firearm.

Beckey gave Detective Ethan Haworth and members of the Washington County Sheriff’s

Department consent to search the lower level of their home, where Appellant, Beckey, and three

2 The domestic violence allegations against Appellant are not in issue in this appeal.

2 grandchildren lived.3 Beckey showed them a locked safe, which she unlocked using a key in her

possession. The safe contained fifteen firearms and ammunition, which the officers seized.

Appellant was not present during the search because he was already in custody.

On December 21, 2018, Beckey contacted the Sheriff’s Department again and informed

them Appellant had two antique, black powder firearms in the house. The antique firearms were

not discovered during the first search because they were in a closet, not in the safe with the other

firearms. Detective Haworth returned to the home and seized the antique firearms.

2. The Trial

a. The State’s Case

The State charged Appellant with fifteen counts of unlawful possession of a firearm for

the fifteen guns in the safe. Appellant was not charged with possession of the antique firearms.

The State expected to call three witnesses at trial: Beckey, Detective Haworth, and Corrections

Officer Cody Bennett.

During opening statements, the State told the jury Beckey would testify Appellant had

keys to the gun safe, owned the guns in the safe, and frequently used the guns. The State also

said Beckey would testify she periodically purchased guns on Appellant’s behalf. Beckey did

not testify at trial, purportedly because she had a medical emergency requiring hospitalization.4

Officer Bennett was a corrections officer at the facility where Appellant was held after

his arrest. Officer Bennett testified Appellant “said he was being charged with the [antique]

handgun that he had, but not the guns in the safe.” The State argued Appellant’s statement to

3 Two additional family members lived in the upper floor of the home. 4 The record is unclear whether Beckey ever intended to testify. She never appeared for depositions despite Appellant’s subpoenas. Further, on-record conversations between the State, Appellant, and the trial court indicate there was some expectation she would not cooperate.

3 Officer Bennett established Appellant knew of the guns in the safe and considered them his

property.

Detective Haworth testified about the Sheriff’s Department’s search of the home and

seizure of firearms and ammunition. Over Appellant’s objection, Detective Haworth testified

Beckey told him Appellant “had several firearms at their home, and so that’s what prompted

[Detective Haworth] to go [to Appellant’s home].” Appellant argued Detective Haworth’s

recitation of Beckey’s out-of-court statements constituted inadmissible hearsay because they

involved an element of section 571.070: Appellant’s possession and control of the firearms in the

safe. The State argued Detective Haworth’s statement was admissible for the non-hearsay

purpose of explaining subsequent police conduct, the search of Appellant’s home. The trial court

permitted Detective Haworth to make the statement for purposes of explaining his subsequent

conduct, based on the State’s representation Beckey would testify to the same facts on direct

examination.5

On cross-examination, Appellant’s trial counsel asked Detective Haworth, “You

ultimately went to Beckey Hollowell's residence because she's the one who provided you with

information that there were firearms, correct?” Detective Haworth replied, “Yes.” During

argument on Appellant’s motion for acquittal at the close of the State’s evidence, the State

argued trial counsel’s question introduced Beckey’s statement Appellant possessed the guns in

the safe into evidence without limitation, waiving Appellant’s earlier objection. The trial court

agreed and denied Appellant’s motion for acquittal.

5 Before permitting Detective Haworth to testify about Beckey’s statements, the trial court stated, “Once again, I'm going to assume that she's going to be here to testify as to these facts, but at the same time -- I'm making an assumption that may or may not be correct, but I'm assuming that.” Following Appellant’s conviction, the trial court stated it would have restricted Beckey’s statement further had the court known Beckey was not going to testify.

4 The State used Beckey’s claim Appellant possessed the guns for its truth in closing

argument. The prosecutor argued to the jury:

Now, you also heard that Beckey Hollowell, his wife, told Detective Haworth that

the guns belonged to Eric. That was her statement, that the guns belonged to Eric,

not to her. So could that – could Eric exercise control over the guns? Absolutely.

If he had the keys with him, obviously.

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Related

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143 S.W.3d 36 (Missouri Court of Appeals, 2004)
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49 S.W.3d 181 (Supreme Court of Missouri, 2001)
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In the Interest of G.D.
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State of Missouri v. Eric G. Hollowell, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-missouri-v-eric-g-hollowell-moctapp-2021.