State v. Ball
91 A.L.R. 2d 1042, 1960 Mo. LEXIS 613, 339 S.W.2d 783 (1960)
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Rule of Law:
The mere possession of a quantity of money by a defendant is inadmissible as evidence of a robbery unless the prosecution can either directly connect the money to the crime or show the defendant's sudden, unexplained affluence following the crime contrasted with prior impecuniousness.
Facts:
- On October 15, 1958, two men, one tall and one short, entered the Krekeler Jewelry Store in the afternoon to look at merchandise.
- Later that day, the same two men returned to the store as the owner, John Krekeler, was preparing to close.
- The shorter man pointed a long-barreled .38 gun at Krekeler.
- The men forced Krekeler into a restroom in the back of the store and told him to face the wall.
- The men stole jewelry valued at $4,455.21 and $140 in cash from the cash register.
- Three weeks later, on November 4, 1958, police identified William Arthur Ball as the taller of the two men.
- When officers attempted to arrest Ball, he fled and was subsequently shot and subdued.
- Upon his arrest, police found $258.02 in cash on Ball's person.
Procedural Posture:
- William Arthur Ball was tried for robbery in the first degree in a Missouri trial court.
- A jury found Ball guilty and also found prior felony convictions.
- The trial court imposed a mandatory sentence of life imprisonment.
- Ball filed a motion for a new trial, which was denied.
- Ball, as appellant, appealed his conviction and sentence to the Supreme Court of Missouri.
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Issue:
Does the admission of evidence that a defendant possessed a large sum of money at the time of his arrest, weeks after the robbery and with no proof linking it to the stolen funds, constitute prejudicial error requiring a new trial?
Opinions:
Majority - Barrett, Commissioner
Yes. The admission of the money into evidence was prejudicial error because it was not relevant to the crime charged. For such evidence to be admissible, the prosecution must lay a foundation by either linking the money to the funds stolen or by demonstrating the defendant's prior impecuniousness and sudden affluence after the crime. Here, nineteen days had passed since the robbery, the amount found ($258.02) did not match the amount stolen ($140), and the victim could not identify the money. Furthermore, the state offered no proof that Ball was without money before the robbery and suddenly possessed it afterward. Admitting this evidence was highly prejudicial because it may have led the jury to improperly infer that Ball was guilty of another robbery, thereby infringing his right to a fair trial on the specific offense charged.
Analysis:
This decision reinforces the fundamental evidentiary principle of relevance, establishing a clear standard for the admissibility of money found in a defendant's possession after a theft-related crime. It prevents the prosecution from introducing evidence that serves only to create a generalized suspicion of the defendant's character or involvement in other criminal activity. The case establishes a crucial protection for defendants by requiring a direct nexus between the evidence and the specific crime charged, forcing the state to prove either a transactional link or a stark, unexplained change in financial status. This precedent ensures that convictions are based on evidence probative of the actual offense, not on prejudicial inferences about a defendant's lifestyle or the source of their money.
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