State of Missouri v. James L. Lancaster

Ozark, Missouri third-degree domestic violence criminal defense lawyer represented the Defendant.

James L. Lancaster was charged with third-degree domestic assault.



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"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 ....'" Jackson-Bey, 690 S.W.3d at 184-85 (citing State ex rel. Kemper v. Vincent, 191 S.W.3d 45, 50 (Mo. banc 2006)). This rule ensures no evidence is admitted out of context. State v. Marshall, 410 S.W.3d 663, 672 (Mo. App. S.D. 2013) (quoting State v. Jackson, 313 S.W.3d 206, 211 (Mo. App. E.D. 2010)).



Two conditions must be met for the rule of completeness to apply: (1) "the item sought to be introduced is part of a greater whole" and (2) "[t]he parts introduced to complete the whole .... relate to the same subject matter as that which has been admitted." State v. Ellis, 512 S.W.3d 816, 826 (Mo. App. W.D. 2016) (quoting 22 Andrea Bell, Missouri Practice, Missouri Evidence §106:1 (4th ed. 2012)). The rule of completeness does not allow for "unfettered admission of any and all statements." State v. Graham, 529 S.W.3d 363, 367 (Mo. App. E.D. 2017). Generally, the rule of completeness is only violated when admission of the statement in an edited form distorts the meaning of the statement or excludes information which is substantially exculpatory to the declarant. Ellis, 512 S.W.3d at 827-28.

The Defendant was found guilty.



Affirmed.



State v. Lancaster, SD38300 (Mo. App. Aug 26, 2024)