State of Missouri v. Troy Jackson-Bey

CourtSupreme Court of Missouri
DecidedApril 30, 2024
DocketSC100188
StatusPublished

This text of State of Missouri v. Troy Jackson-Bey (State of Missouri v. Troy Jackson-Bey) is published on Counsel Stack Legal Research, covering Supreme Court of Missouri 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. Troy Jackson-Bey, (Mo. 2024).

Opinion

SUPREME COURT OF MISSOURI en banc STATE OF MISSOURI, ) Opinion issued April 30, 2024, ) and modified on the Court’s own Respondent, ) motion July 9, 2024 ) v. ) No. SC100188 ) TROY JACKSON-BEY, ) ) Appellant. )

APPEAL FROM THE CIRCUIT COURT OF THE CITY OF ST. LOUIS The Honorable Paula P. Bryant, Judge

Troy Jackson-Bey appeals from a judgment convicting him of five counts,

including first-degree murder and first-degree assault. On appeal, Jackson-Bey

challenges the circuit court’s admission of surveillance video, the submission of the

verdict director for first-degree assault, and the sufficiency of evidence supporting his

convictions. The circuit court did not err in admitting the surveillance video, submitting

the first-degree assault verdict director, and in finding there was sufficient evidence

supporting Jackson-Bey’s convictions. The judgment is affirmed.

Background

A jury found Jackson-Bey guilty of five counts, including first-degree murder and

first-degree assault, stemming from an altercation occurring in June 2020 at Husband and Wife’s residence. Viewed in the light most favorable to the verdict, the evidence adduced

at trial included: Jackson-Bey and Husband got into an argument after Husband asked a

woman to move her parked car forward so he could park his car in front of Husband and

Wife’s residence. The woman moved her car. Jackson-Bey, who was angry at Husband’s

request, approached Husband, who was exiting his car. The two argued. The argument

appeared to end, and Jackson-Bey turned to walk away but then drew his gun and shot

Husband.

Wife, who had been watching from the window, screamed and ran toward the door.

Jackson-Bey forced his way through the door and fired his weapon. A struggle for control

of the gun ensued between Wife and Jackson-Bey, during which Jackson-Bey fired his gun.

Jackson-Bey again fired the gun between Wife’s legs and then exited the residence. 1 Wife

was not shot. Husband, who sustained six gunshot wounds, died.

Prior to trial, Jackson-Bey filed a motion in limine, seeking to exclude surveillance

video taken from Husband and Wife’s residence, arguing, under the rule of completeness,

he was entitled to present the entire surveillance video of which the State had offered

only portions. Opposing the motion, the State explained the video clips were created

from a motion-detection system, such that the cameras did not record continuously but,

instead, recorded in 30-second intervals. 2 The circuit court overruled the motion in

limine. At trial, Wife testified she and Husband had a security system at their residence

1 At trial, the State offered ballistic evidence, which included a bullet casing found in the residence and gunfire damage to the living room wall. 2 The State sought to introduce five video clips, which were combined into one exhibit. 2 that included three cameras. She testified the system used a motion-detecting sensor, and

the camera recorded in 30-second increments. She testified the security system recorded

some of the incidents involved in the case. The circuit court, over Jackson-Bey’s

objection, admitted into evidence the surveillance video, which was shown to the jury.

The State submitted five counts to the jury. Relevant here, the verdict director for

first-degree assault authorized the jury to convict Jackson-Bey of first-degree assault if it

found, in part: “That on or about June 16, 2020, in the State of Missouri, [Jackson-Bey]

attempted to kill or cause serious physical injury to [Wife] by shooting her.” 3 (Emphasis

added). Jackson-Bey did not object to the verdict director’s language. During closing

argument, Jackson-Bey argued the jury could not convict him of first-degree assault

because there was no evidence he shot Wife. Also during closing argument, Jackson-Bey

stated the first-degree murder instruction included: “The defendant was 18 years of age or

older at the time of the offense.” 4 He argued the State had not presented any evidence as

to his age and the State had to prove this element beyond a reasonable doubt.

The jury found Jackson-Bey guilty of all five counts. Jackson-Bey appealed. This

Court granted transfer after opinion by the court of appeals. Mo. Const. art. V, sec. 10.

I. Surveillance Video

The first issue before this Court is whether the circuit court erred in admitting the

surveillance video into evidence.

3 Also relevant here, the indictment charged Jackson-Bey with first-degree assault in that: “on or about June 16, 2020, … [he] shot at … [Wife] ….” (Emphasis added). 4 The first-degree murder instruction was patterned after MAI-CR 4th 414.02. 3 Standard of Review

This Court reviews a circuit court’s admission or exclusion of evidence for abuse

of discretion. State v. Minor, 648 S.W.3d 721, 735 (Mo. banc 2022). A circuit court

abuses its discretion if its decision is “clearly against the logic of the circumstances then

before the court and is so unreasonable and arbitrary that it shocks the sense of justice

and indicates a lack of careful, deliberate consideration.” State v. Carpenter, 605 S.W.3d

355, 359 (Mo. banc 2020) (internal quotations omitted). This Court will reverse only if

the alleged circuit court error was so prejudicial it deprived the defendant of a fair trial.

Id. at 370.

Analysis

Jackson-Bey contends the circuit court erred in admitting the surveillance video

because, pursuant to the rule of completeness, he was entitled to introduce the entire

surveillance video. Jackson-Bey’s argument fails, however, because the rule of

completeness does not apply.

The rule of completeness provides that, when “either party introduces part of an

act, occurrence, or transaction, the opposing party is entitled to introduce or to inquire

into other parts of the whole thereof in order to explain or rebut adverse inferences which

might arise from the fragmentary or incomplete character of the evidence introduced by

his adversary ….” State ex rel. Kemper v. Vincent, 191 S.W.3d 45, 50 (Mo. banc 2006)

(internal quotations omitted). “The rule of completeness only applies when the item

sought to be introduced is part of a greater whole” and the “parts introduced to complete

4 the whole … relate to the same subject matter” as that previously admitted. State v. Ellis,

512 S.W.3d 816, 826 (Mo. App. 2016) (alteration in original) (internal quotations

omitted).

Jackson-Bey has not shown the admitted video was “part of a greater whole.” At

trial, Wife testified the surveillance system recorded in 30-second increments upon

motion detection. The record supports there was no single, continuous video, but, rather,

each 30-second clip, itself, was a complete video, triggered by motion detection.

Jackson-Bey relies on United States v. Yevakpor, 419 F. Supp. 2d 242 (N.D.N.Y.

2006), in which the district court excluded the government’s proffered evidence of three,

one-minute video segments taken from surveillance recording of a border stop and

search. Id. at 244-45. Relying on the rule of completeness, the district court observed

that customs had failed to preserve the entire video and, in fact, gave an affirmative order

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State of Missouri v. Troy Jackson-Bey, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-missouri-v-troy-jackson-bey-mo-2024.