State of Missouri v. Jackson-Bey
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The case revolves around Troy Jackson-Bey, who was convicted of five counts, including first-degree murder and first-degree assault, following an altercation at a residence. The altercation began when Jackson-Bey and another man argued over a parking issue. Jackson-Bey shot the man, who later died from his injuries. Jackson-Bey then forced his way into the man's home, where he fired his weapon multiple times during a struggle with the man's wife. The wife was not shot. Jackson-Bey appealed his conviction, challenging the admission of surveillance video, the submission of the verdict director for first-degree assault, and the sufficiency of evidence supporting his convictions.
The Circuit Court of the City of St. Louis had previously ruled against Jackson-Bey's motion to exclude surveillance video taken from the residence. The court also found there was sufficient evidence supporting Jackson-Bey’s convictions. Jackson-Bey appealed these decisions.
The Supreme Court of Missouri affirmed the lower court's decisions. The court found that the circuit court did not err in admitting the surveillance video, as the rule of completeness did not apply. The court also ruled that there was sufficient evidence to support Jackson-Bey’s first-degree assault conviction, as the jury could have reasonably found that Jackson-Bey attempted to kill or cause serious physical injury to the wife. Lastly, the court concluded that age is not an element of the offense of first-degree murder, and thus, it was not necessary for the state to prove Jackson-Bey was 18 years or older at the time of the offense.
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