State of Missouri v. Mark Aaron

CourtMissouri Court of Appeals
DecidedApril 25, 2023
DocketED110394
StatusPublished

This text of State of Missouri v. Mark Aaron (State of Missouri v. Mark Aaron) 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. Mark Aaron, (Mo. Ct. App. 2023).

Opinion

In the Missouri Court of Appeals Eastern District DIVISION THREE

STATE OF MISSOURI, ) No. ED110394 ) Respondent, ) Appeal from the Circuit Court ) of St. Louis County v. ) Cause No. 20SL-CR03875-01 ) MARK AARON, ) Honorable Stanley J. Wallach ) Appellant. ) Filed: April 25, 2023

I. Introduction Mark Aaron appeals the judgment entered after a jury found him guilty of first-degree

assault, armed criminal action, and unlawful possession of a firearm. We affirm.

II. Background

Aaron’s convictions stem from a shooting on August 18, 2020. After becoming concerned

about the whereabouts of a missing cellphone, Aaron and his girlfriend went to Marcus Recar’s

and his girlfriend’s residence. Soon after their arrival, Aaron’s girlfriend and Recar’s girlfriend

began to fight. Aaron, a convicted felon, picked up a firearm from his girlfriend’s sweatshirt and

shot Recar four times. Aaron and his girlfriend fled from the scene, and a neighbor called the

police.

Although Aaron did not testify at trial, Aaron’s girlfriend advanced a theory of self-defense

on his behalf. She testified that Aaron shot Recar after Recar moved first towards her before

1 changing directions and charging towards Aaron with a metal pipe. Recar and his girlfriend both

testified that Recar was unarmed during the entirety of the incident.

After the shooting, Dr. Matthew Pieper, a trauma surgeon, treated Recar at Saint Louis

University Hospital Trauma Center. At trial, Dr. Pieper testified about Recar’s surgery and the

extent of his injuries. Over Aaron’s objection, the State introduced into evidence a photograph of

Recar’s torso showing a large opening in his abdomen covered by a black sponge and a small

gunshot wound above it. Dr. Pieper testified that the photograph showed Recar’s abdomen during

an initial “damage-control surgery” and that the sponge served as a “dressing that is covering his

internal organs.” Dr. Pieper also testified, over Aaron’s objection, about the pain that an individual

would be expected to experience after being shot.

The jury found Aaron guilty of first-degree assault, armed criminal action, and unlawful

possession of a firearm. This appeal follows. In his three points on appeal, Aaron challenges the

admission of the photograph of Recar after surgery and the admission of expert testimony

regarding the pain a person experiences after being shot.

III. Standard of Review

A circuit court has broad discretion to admit or exclude evidence at trial. State v. Blurton,

484 S.W.3d 758, 779 (Mo. banc 2016). We will reverse a circuit court’s decision to admit evidence

only if the circuit court abused its discretion and the opponent of the evidence was thereby

prejudiced. State v. Hughes, 469 S.W.3d 894, 902 (Mo. App. E.D. 2015). “An abuse of discretion

must be clearly against the logic of the existing circumstances and so arbitrary and unreasonable

as to shock the sense of justice and indicate a lack of careful consideration.” Id. “To prevail on

appeal, the defendant must demonstrate prejudice, not mere error, and we will reverse only if the

error was so prejudicial that it deprived the defendant of a fair trial.” State v. Forster, 616 S.W.3d

2 436, 445 (Mo. App. E.D. 2020) (internal quotation marks and citations omitted). The test for

prejudice is outcome-determinative and requires a finding that, “when considered with and

balanced against all evidence properly admitted, there is a reasonable probability that the jury

would have acquitted but for the erroneously admitted evidence.” State v. Black, 50 S.W.3d 778,

786 (Mo. banc 2001).

IV. Discussion

In order to be admissible, evidence must be both logically and legally relevant. Blurton,

484 S.W.3d at 777. “Evidence is logically relevant if it tends to make the existence of a material

fact more or less probable.” Id. (quoting State v. Taylor, 466 S.W.3d 521, 528 (Mo. banc 2015)).

“Evidence is legally relevant when the probative value of the evidence outweighs its costs, such

as unfair prejudice, confusion of the issues, misleading the jury, undue delay, waste of time, or

cumulativeness.” Id. (internal quotation marks and citation omitted).

Admission of Photograph

In his first point on appeal, Aaron asserts that the circuit court abused its discretion by

admitting the photograph of Recar’s torso. Aaron does not contest the logical relevance of the

photo. Rather, he contends that the photograph was so “shocking and gruesome,” its probative

value was outweighed by its prejudicial impact. Specifically, Aaron contends that the photograph

was cumulative to the testimony regarding the extent of Recar’s injuries and that, because the

seriousness of the injury was not contested, the photograph served no purpose but to arouse

emotion in the jury.

“Photographs are admissible if they accurately and fairly represent what they purport to

depict and tend to prove or disprove any of the elements of the charged offense.” State v. Cannady,

389 S.W.3d 306, 312 (Mo. App. S.D. 2013) (internal quotation marks and citation omitted). Even

3 if a photograph may be inflammatory, it should not be excluded if it is relevant. State v. Rousan,

961 S.W.2d 831, 844 (Mo. banc 1998). A photograph is relevant if it “show[s] the scene of the

crime, the identity of the victim, the nature and extent of the wounds, the cause of death, the

condition and location of the body, or otherwise constitute[s] proof of an element of the crime or

assist[s] the jury in understanding the testimony.” Id. If a photograph is shocking or gruesome, it

is generally because the crime itself was shocking or gruesome. Id. Additionally, “a photograph is

not rendered inadmissible because other evidence may have described what is shown in the

photograph; nor is the State precluded from introducing the photograph because the defendant

expresses a willingness to stipulate to some of the issues involved.” Forster, 616 S.W.3d at 446

(internal quotation marks and citations omitted).

Here, Aaron characterizes the admitted photograph as “grotesque” and “gruesome” and

contends that it served no other purpose than to inflame the jury. While the photograph may be

unpleasant as a result of the medical dressing and gunshot wound, it depicts the seriousness of the

injuries sustained by Recar following his medical surgery. The photograph was relevant to show

the nature of the wounds and assisted the jury in understanding Dr. Pieper’s testimony. Moreover,

we do not find the photograph particularly gruesome. It is a post-surgical photograph in which all

blood has been cleared away. Although Recar’s abdomen was opened during the surgery, the

whole of the surgical site is covered with a large black sponge such that nothing internal remains

visible. To the extent that the photograph may be considered gruesome, that would only be a result

of the gruesome nature of the crime.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Rousan
961 S.W.2d 831 (Supreme Court of Missouri, 1998)
Lineberry v. Shull
695 S.W.2d 132 (Missouri Court of Appeals, 1985)
State v. Black
50 S.W.3d 778 (Supreme Court of Missouri, 2001)
State of Missouri v. Demetrick Taylor
466 S.W.3d 521 (Supreme Court of Missouri, 2015)
State of Missouri v. Marcus Hughes
469 S.W.3d 894 (Missouri Court of Appeals, 2015)
State of Missouri v. Robert Blake Blurton
484 S.W.3d 758 (Supreme Court of Missouri, 2016)
State v. Cannady
389 S.W.3d 306 (Missouri Court of Appeals, 2013)
State v. Wright
562 S.W.3d 311 (Missouri Court of Appeals, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
State of Missouri v. Mark Aaron, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-missouri-v-mark-aaron-moctapp-2023.