State v. Guyton
1982 Mo. App. LEXIS 3563, 635 S.W.2d 353 (1982)
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Rule of Law:
To hold an accomplice liable for manslaughter, the prosecution must prove the accomplice knowingly and intentionally aided the underlying assault that resulted in the victim's death. This is distinct from felony murder, where liability attaches simply for aiding the commission of the underlying felony during which a death occurs.
Facts:
- On March 4, 1979, Orson Guyton and Reginald Parks entered the City Cousin restaurant.
- After Parks failed to produce identification, the manager, Mack Brindley, and two customers escorted Guyton and Parks to the door.
- At the door, Guyton and Parks each drew a pistol, forced the men back into the restaurant, and announced a robbery.
- Guyton was armed with a .357 magnum and Parks with a .22 caliber pistol.
- Guyton unsuccessfully tried to open the cash register, so Brindley was forced behind the bar to open it.
- While behind the bar, Brindley was fatally shot by a .22 caliber projectile from Parks's gun and also received a non-fatal wound from a .357 magnum.
- Following the shooting, Parks robbed and wounded several other customers.
- Upon exiting, Parks was shot and killed by police, and Guyton was apprehended, later confessing that they had planned to rob the restaurant but denying he shot Brindley or robbed customers.
Procedural Posture:
- Orson Guyton was charged by indictment with eight counts, including first-degree murder, assault, and first-degree robbery.
- At trial in the court of first instance, the jury was instructed on first-degree (felony) murder and the lesser-included offense of manslaughter.
- The jury found Guyton not guilty of first-degree murder and assault, but guilty of one count of manslaughter and three counts of first-degree robbery.
- The trial court sentenced Guyton to four consecutive ten-year terms.
- Guyton (appellant) appealed the convictions to the Missouri Court of Appeals, arguing that his acquittal on the felony murder charge should have also acquitted him of manslaughter.
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Issue:
Does a defendant's acquittal for first-degree felony murder require an acquittal for manslaughter when the jury instructions for both offenses were nearly identical and improperly included the underlying felony as an element of manslaughter?
Opinions:
Majority - Pudlowski, Judge.
No, a defendant's acquittal for first-degree felony murder does not automatically require an acquittal for manslaughter, but the manslaughter conviction must be reversed. The trial court committed plain error by giving a manslaughter jury instruction that was virtually identical to the felony murder instruction, as both improperly required the jury to find the death occurred during a robbery. This misdirection constituted a manifest injustice because it deprived the defendant of a proper jury consideration of the distinct offense of manslaughter. The court clarified that manslaughter is an unintentional killing. To be liable as an accomplice to manslaughter, a defendant must intend to promote the underlying assault that results in death, not the underlying felony (like robbery). One cannot logically intend to promote an unintentional killing. Therefore, the defendant's liability for manslaughter must stem from his intent to aid the assault from which the death unintentionally arose. The case is remanded for a new trial on the manslaughter charge with proper jury instructions.
Analysis:
This case clarifies the critical distinction between accomplice liability for felony murder and for manslaughter. It establishes that for manslaughter, the accomplice's intent must be tied to the specific act causing death (the assault), not merely the general felony being committed. This decision provides a clear blueprint for trial courts on how to properly instruct juries on lesser-included homicide offenses for accomplices, preventing the conflation of different mental states required for distinct crimes. The ruling reinforces the principle that jury instructions must accurately reflect the substantive law to avoid manifest injustice and ensure a defendant is judged on the precise elements of the crime charged.
