State v. St. Clair
40 A.L.R. 2d 903, 262 S.W.2d 25 (1953)
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Rule of Law:
Coercion can excuse lesser crimes (but not the taking of an innocent life) if the threat of death or serious bodily injury is present, imminent, and impending, inducing a well-grounded apprehension, and the coerced individual had no reasonable opportunity to avoid the act without undue exposure to such harm.
Facts:
- William Rieken, who operated a truck garden in Jackson County, was robbed in his home on the night of August 19, 1950, by a man holding a pistol and a flashlight, who stole $325.
- After the intruder left, Rieken saw a truck drive away with men in it and reported the incident to the police, later identifying St. Clair as the robber.
- On August 26, 1950, St. Clair, Loren Young, and Calvin McNeal were arrested at St. Clair's home, where officers found a stolen automobile, firearms, and ammunition.
- St. Clair admitted his involvement in the robbery but claimed Young and McNeal had forced him to participate.
- St. Clair testified that Young and McNeal frequently visited his home, often staying there, engaging in target practice, shooting at him, and threatening to kill him and his wife if he reported them or disobeyed them.
- St. Clair further testified that on the night of the robbery, Young and McNeal forced him to drive his truck, threatened to 'punch' him, and then threatened to 'blow my head out' and shoot his wife and son if he did not go through with the holdup of Rieken.
- McNeal gave St. Clair an unloaded pistol and displayed a sawed-off shotgun, standing at Rieken's door while St. Clair entered and robbed Rieken as instructed.
- After the robbery, McNeal took the money and pistol from St. Clair, and Young then revealed the pistol used was unloaded.
- Medical evidence indicated St. Clair suffered from organic brain disease, making him easily swayed by threats and prone to insane fear of two men, and he was previously committed to a state hospital as insane in 1943.
Procedural Posture:
- St. Clair was charged with robbery in the first degree in the Circuit Court of Jackson County.
- A jury found St. Clair guilty of robbery in the first degree, and he was sentenced to imprisonment.
- St. Clair appealed his conviction and sentence to the Supreme Court of Missouri, assigning error in the refusal to instruct on duress, in the admission and exclusion of evidence, and in the denial of a motion for mistrial.
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Issue:
Does the defense of duress require an instruction to the jury when evidence suggests the defendant committed robbery under a well-grounded fear of present, imminent, and impending death or serious bodily injury, with no reasonable opportunity to avoid the act?
Opinions:
Majority - Hollingsworth, Judge
Yes, the trial court erred in refusing to instruct the jury on the issue of duress. The court affirmed that while coercion does not excuse the taking of an innocent life, it can excuse lesser crimes if certain conditions are met: the coercion must be present, imminent, and impending, of such a nature as to induce a well-grounded apprehension of death or serious bodily injury if the act is not done, and the defendant must not have a reasonable opportunity to avoid the act without undue exposure to such harm. The evidence presented by St. Clair, if believed by the jury, would have justified a finding that he committed the robbery not of his own volition, but due to a well-grounded fear of present, imminent, and impending death or serious bodily injury from Young and McNeal. Furthermore, his testimony that McNeal was under immediate surveillance with a drawn shotgun at Rieken's door would warrant a finding that he had no reasonable opportunity to avoid the robbery without immediate exposure to harm. Therefore, the issue of duress was submissible to the jury, and failure to instruct on it was reversible error. The court also held that a certified copy of a prior judgment adjudging St. Clair insane was admissible evidence bearing on his mental condition at the time of the robbery, and its exclusion was error.
Analysis:
This case establishes a critical precedent in Missouri criminal law regarding the defense of duress, adopting a widely accepted test for its application. By clarifying the subjective and objective elements required—a well-grounded apprehension of imminent harm and a lack of reasonable escape opportunity—the ruling ensures that defendants who can provide evidence meeting these criteria are entitled to have a jury consider this defense. This decision reinforces the principle that criminal intent (mens rea) can be negated by extreme coercion, thereby protecting individuals forced into criminal acts against their will, while still maintaining strict standards for the defense.
