State of Missouri v. Eric Lawson

CourtMissouri Court of Appeals
DecidedMay 9, 2023
DocketED109743
StatusPublished

This text of State of Missouri v. Eric Lawson (State of Missouri v. Eric Lawson) 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 Lawson, (Mo. Ct. App. 2023).

Opinion

In the Missouri Court of Appeals Eastern District SPECIAL DIVISION

STATE OF MISSOURI, ) No. ED109743 ) Respondent, ) Appeal from the Circuit Court ) of the City of St. Louis vs. ) 1222-CR02611-01 ) ERIC LAWSON, ) Honorable Michael W. Noble ) Appellant. ) FILED: May 9, 2023

Introduction

Eric Lawson (Appellant) appeals from the judgment convicting him of three counts of

murder in the first degree, one count of assault in the first degree, one count of arson in the first

degree resulting in death, five associated counts of armed criminal action, and two counts of

endangering the welfare of a child in the first degree. Appellant was sentenced to serve

consecutive sentences of life without parole for each offense of first-degree murder, life for the

offenses of first-degree assault and first-degree arson resulting in death, 30 years for each of the

associated offenses of armed criminal action, and seven years for each offense of endangering

the welfare of a child. For the following reasons, we affirm. Factual and Procedural Background

Appellant does not challenge the sufficiency of the evidence supporting his convictions.

We therefore only briefly summarize the evidence presented at trial, viewed in the light most

favorable to the verdict. 1

Appellant was charged with three counts of first-degree murder, one count of first-degree

assault, one count of first-degree arson resulting in death, five associated counts of armed

criminal action (ACA), and two counts of first-degree endangering the welfare of a child

stemming from the deaths of his former girlfriend, Breiana Ray, her mother, Gwendolyn Ray, 2

and his and Breiana’s ten-month-old son, A.L., in addition to injuries to Breiana’s three-year-old

daughter, M.R.

On the evening of May 5, 2012, Gwendolyn’s home was set on fire. First responders

were dispatched to the home shortly after 10:00 P.M. Upon entering the home, firefighters found

M.R. walking around; she lost consciousness while firefighters rescued her from the home, but

was resuscitated by paramedics and taken to the hospital. Firefighters discovered A.L.

unconscious next to Breiana, who was dead with an apparent gunshot wound to her head.

Gwendolyn was also found dead with an apparent gunshot wound to the head. Firefighters

attempted to resuscitate A.L. and he was taken to the hospital, where he died after doctors were

unable to resuscitate him. Fire investigators determined that two fires had been intentionally set

in the home: one in the living room on the first level of the apartment and one in a bedroom on

1 See State v. Collings, 450 S.W.3d 741, 753 (Mo. banc 2014) (citing State v. McFadden, 369 S.W.3d 727, 736 (Mo. banc 2012)). 2 To avoid confusion given the shared family name, we refer to members of the Ray family by their first names. In so doing, we intend no disrespect or familiarity. 2 the second level of the apartment. 3 The cause of both Breiana’s and Gwendolyn’s deaths were

gunshot wounds to the head, and the cause of A.L.’s death was determined to be smoke

inhalation. Appellant was arrested later that night because a witness placed him as the last

individual at the scene of the crimes shortly prior to their commission. After initially denying his

involvement, Appellant confessed to the crimes the following morning. Ballistics evidence

recovered from the crime scene and one victim was later matched to Appellant’s firearm.

The State sought the death penalty for the first-degree-murder charges, which were

severed from the remaining nine charges for trial. A jury trial was held in April and May 2021,

at which Appellant was found guilty of the three counts of first-degree murder. 4 The jury

rejected the death penalty and returned a verdict recommending sentences of life without parole.

The trial court found Appellant guilty of the remaining nine counts after a bench trial, 5 and

sentenced Appellant to consecutive sentences of life without parole for each offense of first-

degree murder, life for the offenses of first-degree assault and first-degree arson resulting in

death, 30 years for each of the associated ACA offenses, and seven years for each offense of

endangering the welfare of a child. This appeal follows.

We include further facts as necessary in our discussion of each of Appellant’s points on

appeal.

Discussion

In his seven points on appeal, Appellant presents various challenges to his jury trial of the

three murder offenses. In Point I, Appellant argues his jury panel should have been quashed

3 Gwendolyn’s home was a two-story apartment on the second and third levels of a brick building. 4 Appellant’s first trial on these charges resulted in a mistrial due to an inability to seat a sufficient number of jurors. 5 Appellant waived his right to a trial by jury and the parties stipulated that the entire record of the jury trial proceedings would be admitted into evidence at the bench trial. 3 because he made a prima facie showing that the pool from which his jury was drawn failed to

represent a fair cross-section of the community. In Point II, Appellant challenges the denial of

his motion to suppress and the admission at trial of his incriminating statements to law

enforcement officers based on a claim that the waiver of his rights was invalid and his statements

were coerced. In Point III, Appellant asserts his incriminating statements should have been

suppressed because they were the product of an illegal arrest without probable cause. In Point

IV, Appellant contends the trial court erred in limiting defense counsel’s cross-examination of

the lead investigating officer. In Point V, Appellant disputes the admissibility of a video of an

attempted Child Advocacy Center interview with the surviving victim of the fire. In Point VI,

Appellant claims error in the admission of testimony from physicians who treated the two child

victims, one of whom survived the fire. And lastly, in Point VII, Appellant challenges the failure

to issue his requested alibi instruction.

For the reasons discussed below, we conclude that none of Appellant’s points on appeal

are meritorious.

Fair Cross-Section (Point I)

In his first point, Appellant argues the trial court erred in failing to quash his jury panel

because he made a prima facie showing that the pool from which his jury was drawn failed to

represent a fair cross-section of the community. We conclude the trial court did not err in failing

to quash the jury panel because Appellant did not meet his burden of making this prima facie

showing.

As part of the right to a jury trial guaranteed by the Sixth Amendment and the Missouri

Constitution, criminal defendants have a right to have a jury panel drawn from a fair cross-

4 section of the community. State v. Reed, 502 S.W.3d 79, 87 (Mo. App. E.D. 2016) (citing State

v. Anderson, 79 S.W.3d 420, 430 (Mo. banc 2002)); see Berghuis v. Smith, 559 U.S. 314, 319

(2010) (citing Taylor v. Louisiana, 419 U.S. 522, 528 (1975)). 6 This right guarantees the

opportunity for a representative jury and, as such, requires only that “the jury wheels, pools of

names, panels, or venires from which juries are drawn must not systematically exclude

distinctive groups in the community and thereby fail to be reasonably representative thereof.”

Taylor, 419 U.S. at 538.

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State of Missouri v. Eric Lawson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-missouri-v-eric-lawson-moctapp-2023.