State v. Edwards
30 S.W.3d 226, 2000 WL 1617749, 2000 Mo. App. LEXIS 1617 (2000)
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Rule of Law:
Under Jackson v. Denno, a defendant has a constitutional right to a preliminary hearing outside the presence of the jury to determine the voluntariness of a confession before it is introduced as evidence at trial.
Facts:
- On May 18, 1998, Gerald Edwards (Appellant) got into a car with Edward Harris and Jahmel Luster.
- Edwards saw that Harris was armed with an assault rifle and knew Luster had a semiautomatic pistol.
- Edwards agreed to drive the car and circled a neighborhood, spotting Anthony Atkins on a street corner.
- After circling back, Edwards drove to the corner where Atkins was standing with several teenage girls.
- As Edwards approached the stop sign, Harris and Luster opened fire on the group.
- Anthony Atkins was fatally shot, and two of the girls sustained gunshot wounds.
- Edwards sped away from the scene after the shooting.
- Edwards later instructed his girlfriend to dispose of the assault rifle used in the shootings.
Procedural Posture:
- Gerald Edwards (Appellant) was arrested and made incriminating statements to police.
- At trial, Edwards' counsel made an oral motion to suppress the statements as involuntary.
- The trial court judge denied a separate hearing and decided to 'take the motion with the case,' considering it during the trial in front of the jury.
- The trial court ultimately overruled the motion to suppress.
- A jury in the trial court found Edwards guilty of second-degree murder, two counts of first-degree assault, and three counts of armed criminal action.
- Edwards appealed his convictions to the Missouri Court of Appeals, Eastern District, which is the intermediate appellate court.
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Issue:
Does a trial court violate a defendant’s constitutional rights by failing to hold a preliminary hearing outside the presence of the jury to determine the voluntariness of a confession before admitting it into evidence?
Opinions:
Majority - George W. Draper, III
Yes. A trial court violates a defendant's constitutional rights by failing to hold a preliminary hearing outside the jury's presence to determine the voluntariness of a confession before its admission. The U.S. Supreme Court's decision in Jackson v. Denno establishes that a defendant is entitled to a clear-cut determination by the trial judge on the voluntariness of a confession following an adequate hearing. Missouri practice requires this hearing to be conducted out of the jury's presence to protect the defendant's rights, as the defendant cannot be expected to testify about coercive circumstances in front of the jury without prejudice. Although a trial court has discretion to hear some motions 'with the case,' this discretion does not apply to challenges of a confession's voluntariness when the defendant objects. The proper remedy for this error is not an automatic new trial, but a remand to the trial court for a post-trial evidentiary hearing on the voluntariness of the statements. The court also held there was sufficient evidence for accomplice liability, as Edwards affirmatively participated by driving the car, knowing his passengers were armed, circling the scene, facilitating the escape, and helping dispose of the weapon.
Analysis:
This case reinforces the mandatory procedural safeguard established by Jackson v. Denno, clarifying that a trial court's discretion on hearing motions does not override a defendant's constitutional right to a preliminary hearing on the voluntariness of a confession. It establishes that the remedy for this specific procedural error is a limited remand for a hearing, which is a judicially efficient approach that avoids ordering a full new trial unless the confession is ultimately found to be involuntary. The decision thus preserves judicial resources while protecting a fundamental due process right.
