State v. Maples

551 S.W.3d 634
CourtMissouri Court of Appeals
DecidedJune 26, 2018
DocketWD 79955
StatusPublished
Cited by3 cases

This text of 551 S.W.3d 634 (State v. Maples) 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. Maples, 551 S.W.3d 634 (Mo. Ct. App. 2018).

Opinion

Detective Bearden also testified in Maples's offer of proof. He had interviewed Timothy after the murder. Timothy had denied ever being at Belinda's home or the farm prior to the murder. Detective Bearden also interviewed Chastain. Chastain told Detective Bearden that Timothy had made the following statement to her on January of 2014: "The kid didn't know what he was walking into." Chastain said she did not know who Timothy was referring to when he made that statement. Chastain also said that Timothy made the following statement: "I don't deserve to be alive. I killed her." Chastain again said she did not know who Timothy was referring to. Detective Bearden testified that there was no physical evidence that tied Timothy to Belinda's murder. Chastain, in a statement to law enforcement in March of 2015, stated that Timothy had told her "I killed Bea." Chastain first contacted law enforcement regarding Timothy's admissions of guilt on March 26, 2015, ten days after the *643prosecutor filed a nolle prosequi in the charges against Bob II.

Billy Fahnestock ("Fahnestock") also testified in Maples's offer of proof. At one point, Fahnestock was in the same jail pod as Bob II. During the offer of proof Maples asked Fahnestock to acknowledge a prior statement that Fahnestock made during a deposition regarding Bob II murdering Belinda. However, Fahnestock asserted his rights under the Fifth Amendment to the Constitution and refused to answer most questions and in those that he did answer he said he did not remember making any prior statements.

After the offer of proof, the trial court ruled that Chastain and Fahnestock would not be permitted to testify before the jury. The trial court reserved ruling on whether Seth would be permitted to testify. However, Maples never attempted to call Seth as a witness before the jury or request a final ruling from the trial court on whether he would be allowed to testify.

The jury returned a verdict of guilty of murder in the first degree. On August 5, 2016, the trial court sentenced Maples to life in prison without the possibility of parole. This timely appeal followed.

Discussion

Maples raises four points on appeal. In Maples's first point on appeal, he argues that the trial court erred in admitting his statements to Detective Schlup in the sally port into evidence at trial because it violated his Fifth Amendment rights as he was not provided Miranda warnings prior to his statement. In Maples's second point on appeal, he argues that the trial court erred in admitting his formal statement made on August 22, 2012, because the improper tactics used during the sally port interview rendered the Miranda warning on August 22 ineffective. In Maples's third point on appeal, Maples argues that the trial court erred in admitting his statement made on August 23, 2012, because the improper tactics used in the sally port interview rendered the Miranda warning ineffective. In Maples's fourth point on appeal, he argues that the trial court abused its discretion in sustaining the State's objection to Maples's offer of proof regarding information that Timothy confessed to shooting Belinda because the exclusion of this evidence violated his rights under the Sixth and Fourteenth Amendments since the evidence was exonerating and made under circumstances providing considerable assurance of its reliability.

Analysis of Points One, Two, and Three

Standard of Review

"Review of a trial court's decision as to a motion to suppress evidence is limited to a determination of whether there is substantial evidence to support its decision." State v. Tackett , 12 S.W.3d 332, 336 (Mo. App. W.D. 2000). "The trial court's ruling on a motion to suppress will be reversed only if it is clearly erroneous." State v. Hoyt , 75 S.W.3d 879, 882 (Mo. App. W.D. 2002). "The trial court's ruling is clearly erroneous if this court is left with a definite and firm belief a mistake has been made." Id. "This court reviews the trial court's decision viewing the facts and reasonable inferences therefrom in the light most favorable to the trial court's order with the freedom to disregard contrary evidence and inferences." Id.

State v. Wilson , 169 S.W.3d 870, 875 (Mo. App. W.D. 2005).

Point One

In Maples's first point on appeal, he argues that the trial court erred in admitting the statements he made to Detective Schlup while in the sally port (for ease of reference we will refer to the August 22, *6442012 interview in the jail sally port as the "Sally Port Interview") into evidence at trial over his objection. Maples argues that this ruling violated his Fifth and Fourteenth Amendment rights because the Sally Port Interview was a custodial interrogation and he was not given his Miranda warnings. Maples argues that since he did not receive a Miranda warning before his conversation with Detective Schlup, the statements he made at that time could not be used at trial.

"A criminal suspect is entitled to Miranda warnings, consistent with the Fifth Amendment right against self-incrimination, once the suspect is subjected to a custodial interrogation." State v. McClendon , 477 S.W.3d 206, 212 (Mo. App. W.D. 2015) (quoting State v. Gaw , 285 S.W.3d 318, 321 (Mo. banc 2009) ). "Statements obtained by police during a custodial interrogation not preceded by Miranda warnings are inadmissible in court." Id.

"Custody," under Miranda case law, is a term of art used to specify circumstances that are thought to present a serious danger of coercion. Howes v. Fields , 565 U.S. 499, 509, 132 S.Ct. 1181, 182 L.Ed.2d 17 (2012) (holding that Howes was not in custody within the meaning of Miranda

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Bluebook (online)
551 S.W.3d 634, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-maples-moctapp-2018.