State of Missouri v. James C. Street

CourtMissouri Court of Appeals
DecidedSeptember 14, 2021
DocketED109099
StatusPublished

This text of State of Missouri v. James C. Street (State of Missouri v. James C. Street) 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. James C. Street, (Mo. Ct. App. 2021).

Opinion

In the Missouri Court of Appeals Eastern District DIVISION THREE STATE OF MISSOURI, ) No. ED109099 ) Respondent, ) ) Appeal from the Circuit Court ) of St. Louis County vs. ) Cause No. 15SL-CR02123-01 ) JAMES C. STREET, ) Honorable John D. Warner, Jr. ) Appellant. ) Filed: September 14, 2021

OPINION

James C. Street (“Defendant”) appeals the judgment entered on his conviction after a

bench trial for one count of assault in the third degree. The assault was charged as a class D

felony under § 557.035, known as the Hate Crime statute.1 In his sole cognizable point on

appeal, Defendant claims there was insufficient evidence that he assaulted the victim because of

his race.2 We affirm.

1 This crime occurred in 2015, thus all statutory references are to Mo. Rev. Stat. 2000. The statute has since been amended, but not in any relevant way.

2 Defendant also attempts to raise an ineffective assistance of counsel claim, which is not cognizable on direct appeal and must be presented in a motion under Rule 29.15. See State v. West, 551 S.W.3d 506, 517 (Mo. App. E.D. 2018).

1 I. Procedural and Factual Background

There is no dispute that in March of 2015, Defendant punched Curtis Ford (“Victim”) in

the face with a closed fist at a gas station in Fenton, Missouri. Victim is African-American.

Defendant is Caucasian and Asian. Viewed in the light most favorable to the verdict, the

evidence at the 2019 bench trial was as follows.

As Victim and Defendant pulled into the gas station lot, they had a very brief right-of-

way stalemate near the parking spaces in front of the gas station store. After just a few seconds,

Victim pulled forward out of the way, and Defendant pulled into a parking space. Victim backed

up and then pulled alongside a gas pump. Defendant got out of his car and walked toward

Victim’s car screaming “n----r” at Victim and telling him he did not belong there. Defendant

yelled “N----r, go back to Ferguson” and told Victim he was “acting like a Ferguson n----r right

now.” Victim does not live in Ferguson, and there was no evidence suggesting that Defendant

had any reason to believe that is where Victim lived.3

As Defendant was screaming at him, Victim got out of his car asking what he had done.

Defendant responded with further racial comments, so Victim said something along the lines of

“screw you.” Defendant walked into the gas station store. Victim waited a few moments and then

headed into the store to pre-pay for his gas with cash. He and Defendant met in the doorway, at

which point Defendant said “Hey, this is your lucky day, partner.” Victim said “No, it’s your

lucky day.” Defendant then punched Victim in the face. The entire incident--from the time the

cars met in the parking lot to the time Defendant hit Victim in the doorway of the store--lasted

3 We take judicial notice that, in the seven months preceding this assault, (1) Michael Brown, a Black man, was shot and killed in Ferguson in August of 2014 by a White police officer, (2) the grand jury declined indictment of that officer in November of 2014, and (3) these events sparked both peaceful protests and violent rioting in Ferguson and elsewhere that persisted for months.

2 only a couple of minutes. An eyewitness testified that Defendant called Victim “n----r” at least

ten times in that short period.

The trial court found Defendant guilty, and he was sentenced as a persistent offender to

five years in prison. Execution of that sentence was suspended, and Defendant was placed on

probation.

This appeal follows.

II. Standard of Review

We review the sufficiency of the evidence in a bench trial of a criminal case to determine

whether there was sufficient evidence from which the trier of fact could have reasonably found

the defendant guilty. State v. Banks, 511 S.W.3d 463, 465 (Mo. App. E.D. 2017). We review the

evidence and inferences in the light most favorable to the verdict and ignore all contrary

evidence and inferences. Id. “[We] will not reweigh the evidence on appeal; rather, we give great

deference to the trier of fact, who may believe all, some, or none of the testimony of a witness.”

State v. Young, 582 S.W.3d 84, 95 (Mo. App. E.D. 2019).

III. Discussion

Defendant concedes that he punched Victim, but contends the evidence was insufficient

to prove beyond a reasonable doubt that he did so because Victim was Black. We disagree.

In relevant part, § 557.035 provides that for violations of certain specified sections of the

criminal code, including the section criminalizing assault in the third degree,4 “which the state

believes to be knowingly motivated because of race, color, religion, national origin, sex, sexual

orientation or disability of the victim or victims, the state may charge the crime or crimes under

this section, and the violation is a class D felony.” § 557.035.2. “The court shall assess

4 At the time of this crime, assault in the third degree was codified at § 565.070, but has since been transferred to another section.

3 punishment in all of the cases in which the state pleads and proves any of the motivating factors

listed in this section.” § 557.035.3.

“Because of” in hate crime statutes means that “but for” the victim’s race or other

enumerated characteristics, the defendant would not have committed the crime. See generally

United States v. Miller, 767 F.3d 585, 591-93 (6th Cir. 2014) (discussing United States Supreme

Court and other federal jurisprudence regarding “because of” language in hate crime and other

criminal and civil statutes). Whether a defendant was “motivated because of” one of the

enumerated factors can be inferred from circumstantial evidence, as that is usually the manner in

which motive, intent, or mental state is proven. See State v. Callen, 97 S.W.3d 105, 109-110

(Mo. App. W.D. 2002). Thus, the defendant’s motive for committing the crime can be inferred

from his conduct before, during, and after the crime. Id. at 110-11 (concluding that evidence of

the defendant’s actions before, during, and after trespass was sufficient to demonstrate his “racial

animosity” towards the victim, and the trial court could have reasonably found the trespass on

her property was motivated by her race).

Defendant repeatedly and angrily referred to Victim as a “n----r,” and suggested that

Victim did not belong there and should go “back” to Ferguson. It is reasonable to infer under

these circumstances that Defendant meant Victim did not belong there in Fenton because he was

Black and negatively associated Victim with the recent racial unrest in Ferguson. These racist

statements were made mere moments prior to punching Victim and are clear evidence that the

assault was motivated by Victim’s race. Defendant points out that he did not hit Victim while he

was calling him a “n----r” and that he did not utter any racial slurs at the moment he actually

threw the punch. The passage of those few moments does not in any way diminish the import of

Defendant’s use of racial epithets in determining his motive. It is entirely reasonable to infer that,

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Related

State v. Callen
97 S.W.3d 105 (Missouri Court of Appeals, 2002)
United States v. Samuel Mullet, Sr.
767 F.3d 585 (Sixth Circuit, 2014)
United States v. Randy Metcalf
881 F.3d 641 (Eighth Circuit, 2018)
State v. Banks
511 S.W.3d 463 (Missouri Court of Appeals, 2017)
State v. West
551 S.W.3d 506 (Missouri Court of Appeals, 2018)

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State of Missouri v. James C. Street, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-missouri-v-james-c-street-moctapp-2021.