State of Missouri v. Martin Wright

CourtMissouri Court of Appeals
DecidedApril 23, 2024
DocketED111602
StatusPublished

This text of State of Missouri v. Martin Wright (State of Missouri v. Martin Wright) 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. Martin Wright, (Mo. Ct. App. 2024).

Opinion

In the Missouri Court of Appeals Eastern District DIVISION FOUR

STATE OF MISSOURI, ) No. ED111602 ) Respondent, ) ) Appeal from the Circuit Court of vs. ) Clark County ) 21SY-CR00074-02 ) MARTIN WRIGHT, ) Honorable Rickey R. Roberts ) Appellant. ) Filed: April 23, 2024

Before John P. Torbitzky, P.J., James M. Dowd, J., and Michael S. Wright, J.

OPINION

In this criminal case, appellant Martin Wright appeals his conviction of first-degree

assault after he instigated a bar fight with another patron (Victim) during which he struck Victim

with his fists and caused a serious injury to Victim’s upper lip. In his sole point on appeal,

Wright claims that the trial court abused its discretion by admitting into evidence Exhibit 23 – a

photograph of Victim’s lip shortly before reconstructive surgery – because the State disclosed

the exhibit less than a week before trial despite Wright’s Rule 25.03 1 discovery request made

many months earlier. Wright claims he was prejudiced not only by the lateness of the disclosure,

but because the pre-operative positioning of his lip made the injury look more “gruesome” than it

was which inflamed the jury particularly since the critical issue in this case was whether Wright

1 All rule references are to the Missouri Supreme Court Rules (2022) unless otherwise stated. caused “serious physical injury” to Victim. We disagree and affirm because the State disclosed

Exhibit 23 as soon as practicable, as required by Rule 25.08.

Background

Viewing the evidence in the light most favorable to the verdict, the following evidence

was adduced at trial:

On May 3, 2021, Wright and a friend drove to Buddy’s Place, a bar in Lancaster,

Missouri. Victim was already at the end of the bar speaking to a waitress when they arrived.

Wright sidled up next to Victim as he spoke to the waitress. Victim told Wright to “back off”

and “get out of his space.” Wright declined and only returned to his seat after being asked to do

so several times by Victim and the waitress. Wright then approached Victim again, placed his

hand on Victim’s shoulder, squeezed it, and said, “I’m going to hurt you.” Victim again

protested and Wright retreated. Wright approached Victim for a third time, grabbed his

shoulder, and again threatened him. Victim jerked out of his seat, pushed Wright away from

him, and turned away from Wright to leave the bar when Wright struck him with his fist causing

Victim to fall. Wright repeatedly struck Victim until the waitress and another bar patron pulled

him away.

After the assault, Victim assessed his injuries in the restroom and when he saw blood

covering his face and a gash on his upper lip, he went to a nearby medical clinic which in turn

directed him to go to the hospital. As Victim’s cousin drove him to the hospital, Victim slumped

over and started shaking. His cousin testified Victim lost consciousness as his eyes rolled back.

He later underwent reconstructive surgery to repair the open wound to his upper lip.

The State charged Wright by information with the class A felony of first-degree assault.

On June 4, 2021, over a year before trial began, Wright requested pursuant to Rule 25.03(b)(1)

2 any photographs that “relate to the offense for which defendant is charged.” Less than a week

before trial, the State disclosed five photographs of Victim’s injuries including Exhibit 23, a pre-

operative photograph of Victim’s injury. Wright moved to exclude Exhibit 23 from evidence

because its disclosure was untimely and it was more prejudicial than probative. Wright claimed

that the lateness of the photo’s disclosure – which showed the wound positioned in preparation

for the surgery in a way that made the injury look worse than it was – deprived him of the

opportunity to investigate and authenticate the photograph and to adduce medical evidence or

testimony in response.

For its part, the State represented that Victim provided the photograph to the State shortly

before trial. The prosecutor told the court that he disclosed the photograph to Wright’s counsel

via e-mail as soon as he received it and also telephoned counsel to ensure its receipt.

Additionally, the State claimed that Exhibit 23 was necessary to show that Victim suffered a

serious physical injury. The court agreed finding no discovery violation because the State

disclosed the photograph as soon as it received it from Victim.

At trial, the court admitted Exhibit 23 over Wright’s objection. The jury found Wright

guilty of first-degree assault and the trial court followed the jury’s sentencing recommendation

of ten years in the Missouri Department of Corrections. This appeal follows.

Standard of Review

The trial court has the discretion to decide whether the State violated a rule of discovery.

State v. Johnson, 513 S.W.3d 360, 364 (Mo. App. E.D. 2016). If a violation occurs, the trial

court also has discretion in selecting an appropriate remedy. State v. Willis, 2 S.W.3d 801, 803

(Mo. App. W.D. 1999). “In reviewing an alleged discovery violation, [this Court] must answer

two questions: first, whether the State’s failure to disclose the evidence violated Rule 25.03, and

3 second, if the State violated Rule 25.03, then what is the appropriate sanction the trial court

should have imposed.” State v. Henderson, 410 S.W.3d 760, 764 (Mo. App. E.D. 2013).

We review the trial court’s ruling for an abuse of discretion. Willis, 2 S.W.3d at 803.

“An abuse of discretion occurs where the remedy selected results in fundamental unfairness to

the defendant, or the outcome of the case has been altered.” Id. Fundamental unfairness results

when the State’s failure to disclose evidence results in a defendant’s “genuine surprise” and that

surprise prevents defendant’s “meaningful efforts to consider and prepare a strategy for

addressing the evidence.” State v. Julius, 453 S.W.3d 288, 296 (Mo. App. E.D. 2014). “[T]he

question whether fundamental unfairness resulted turns on whether there was a reasonable

likelihood that timely disclosure of untimely-disclosed evidence would have affected the result

of the trial.” Johnson, 513 S.W.3d at 365.

Discussion

Wright claims that the trial court abused its discretion in admitting Exhibit 23 into

evidence because the State violated the discovery rules when it disclosed the exhibit less than

one week before trial despite Wright’s longstanding discovery request for photographs. Wright

also claims he was prejudiced because the critical issue in the case was whether Wright had

caused Victim a “serious physical injury” and the photograph of Victim’s lip which had been

prepared for surgery showed an injury more severe than he had caused. We disagree.

Rule 25.03(b)(1) states that upon written request by defendant’s counsel, the State is

required to disclose photographs within its possession or control. Rule 25.02(b) states that

discovery requests “shall be answered within fourteen days after service of the request.” The

purpose of Rule 25.03 is to provide the defendant with his due process rights “to prepare his case

in advance of trial and avoid surprise.” Id.

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State v. Walkup
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State v. Rippee
118 S.W.3d 682 (Missouri Court of Appeals, 2003)
State of Missouri v. Brad J. Julius
453 S.W.3d 288 (Missouri Court of Appeals, 2014)
STATE OF MISSOURI, Plaintiff-Respondent v. JAMES ROBERT CROCKER
479 S.W.3d 174 (Missouri Court of Appeals, 2015)
State of Missouri v. Michael L. Johnson
513 S.W.3d 360 (Missouri Court of Appeals, 2016)
State of Missouri v. Danielle Ann Zuroweste
570 S.W.3d 51 (Supreme Court of Missouri, 2019)
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2 S.W.3d 801 (Missouri Court of Appeals, 1999)
State v. Henderson
410 S.W.3d 760 (Missouri Court of Appeals, 2013)
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State of Missouri v. Martin Wright, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-missouri-v-martin-wright-moctapp-2024.