State v. Hicks

526 S.W.3d 273, 2017 WL 2436927, 2017 Mo. App. LEXIS 550
CourtMissouri Court of Appeals
DecidedJune 6, 2017
DocketWD 79610
StatusPublished
Cited by2 cases

This text of 526 S.W.3d 273 (State v. Hicks) 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 v. Hicks, 526 S.W.3d 273, 2017 WL 2436927, 2017 Mo. App. LEXIS 550 (Mo. Ct. App. 2017).

Opinions

James Edward Welsh, Judge

Brian L. Hicks appeals his conviction following a bench trial for one count of first-degree sexual misconduct (§ 566.093, RSMo 1), a class B misdemeanor, for which he was sentenced to 180 days in the Jackson County Department of Corrections. We affirm.

Background

The evidence presented at Hicks’s bench trial showed that, on the morning of June 1, 2015, Patricia Stefancik was at a McDonald’s restaurant with her husband and noticed Hicks sitting at a nearby table. Stefancik could see that Hicks was holding his exposed penis in his hand and masturbating. Stefancik, who identified Hicks at trial, told the judge that she was “shocked to see something like that in public.” Ste-fancik also saw that there was a child [275]*275sitting, nearby, so she notified a McDonald’s employee about the situation.

The police were summoned, 'and Hicks was promptly arrested and taken to a, detention facility where he was “under the control of the City of Independence, its jail staff, and its police department.” That afternoon, Hicks was interviewed by Independence Missouri Police Detective Robert Brady. The detective went over the Miranda2 warnings with Hicks, and Hicks agreed to speak with him.

The interrogation was not recorded, but Detective Brady recounted that Hicks told him that he was masturbating-in the McDonald’s restaurant, and there was a woman there who seemed “alarmed by his behavior.” Hicks told the officer that he did not think anybody could see him where he was at, and he stated that “he didn’t have any intention on harming anybody.”

Psychologist Dr. Eric Gaughan testified for the defense that he had examined Hicks at the Jackson County Detention Center shortly before the trial. The doctor sought to determine- whether Hicks, who has a history of mental health issues, had understood the Miranda warnings when he agreed to speak with Detective Brady.

The circuit court ultimately found Hicks guilty of first-degree sexual misconduct and sentenced him to 180 days in the Jackson County Department of Corrections. Hicks was given credit for time served and released. Hicks appeals.

Discussion

Hicks contends that the circuit court erred in finding .him guilty of sexual misconduct because the State produced no evidence to establish that the crime occurred in the .State of Missouri, in that there was no evidence at trial as to where the McDonald’s restaurant was located, and, thus, the State failed to establish its jurisdiction over the. crime.

We review a claim of insufficient evidence to establish that the crime -occurred in Missouri under.the same standard that we apply to a claim of insufficient evidence. See State v. Williams, 455 S.W.3d 1, 5-6 (Mo. App. 2013) (noting that a claim that the State “failed to prove beyond a reasonable doubt that the crimes occurred in .Missouri” “takes the form of a sufficiency-of-the-evidence challenge”). In reviewing a claim of insufficient evidence in a court-tried criminal case, we are limited to determining whether there is sufficient evidence from which the trial court could have reasonably found the defendant guilty. State v. Vandevere, 175 S.W.3d 107, 108 (Mo. banc 2005). In applying this standard, we accept all evidence and inferences favorable to the judgment as true, and we disregard all evidence and inferences to the contrary. Id. We greatly defer to the trier of fact, and we give equal weight to circumstantial evidence and direct evidence. State v. Shoemaker, 448 S.W.3d 853, 856 (Mo. App. 2014).

Pursuant to section 541.191, Missouri courts have jurisdiction to enforce a criminal law if any element of the crime occurs within the state.3 “Jurisdiction describes the power of a court to try a case.” State v. Taylor, 238 S.W.3d 145, 149 (Mo. banc 2007). “Jurisdictional doctrine prevents courts from holding trials when the [276]*276crime at issue occurred out of state; a state court lacks the authority to enforce criminal law unless the conduct, or some substantial portion of it, occurred within the state.” Id. A court cannot hear a case if it lacks jurisdiction. Id. The standard of proof required to establish jurisdiction in a criminal case has not been definitively resolved in Missouri. Williams, 455 S.W.3d at 6.4 As was the case in Williams, however, we need not decide that issue “because we are convinced that the evidence adduced here was sufficient under the highest standard—beyond a reasonable doubt—to establish that Missouri has jurisdiction.” Id.

Hicks argues that, here, “the State produced no evidence alleging where any element of the crime occurred, thus failing to prove beyond any standard of proof that the crime occurred in Missouri.” (Emphasis added.) He claims that State v. Kleen, 491 S.W.2d 244 (Mo. 1973), is “directly on point.” There, the defendant was convicted in Missouri on an insufficient funds check charge. Id. at 244. The appellate court reversed, finding that, while the check was signed in Missouri, the acts necessary to make the instrument a “check” under the applicable statute (i e., filling in the “amount” and “payable to” sections) occurred later in Tennessee. Id. at 245-46. Thus, the offense was committed in Tennessee, and Missouri did not have jurisdiction. Id. We find Kleen to be distinguishable. There was direct evidence in Kleen that the crime actually occurred in Tennessee. Here, there is no evidence that the crime occurred in another state. As in Williams, however, there is circumstantial evidence from which a reasonable trier of fact could find that the crime occurred in Missouri.

In Williams, the appellant contested his convictions for statutory sodomy by claiming that the State failed to prove that the crimes took place in Missouri. 455 S.W.3d at 5-6. There, the State presented evidence that the defendant would pick up the victim in Arkansas and take her to his home in Missouri. Id. at 7. The appellate court held that, by presenting evidence that the victim visited defendant and that defendant lived at a Missouri residence during the charge period, the State presented sufficient circumstantial evidence for a fact-finder to infer that the alleged crime occurred in Missouri. Id. In response to the appellant’s suggestion that circumstantial evidence could not establish jurisdiction, the Court explained:

[T]he general rule is that “[t]he State may prove its case by presenting either direct or circumstantial evidence connecting the defendant to each element of the crime.” — Here, jurisdiction is not, strictly speaking, an element of [the crime]. Defendant, however, has not cited ... any legal authority supporting the notion that proof of jurisdiction requires any greater evidentiary basis than that required to prove an element of the offense.

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Cite This Page — Counsel Stack

Bluebook (online)
526 S.W.3d 273, 2017 WL 2436927, 2017 Mo. App. LEXIS 550, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-hicks-moctapp-2017.