State of Missouri v. Donald R. Nash

Summary

The Supreme Court of Missouri affirmed Donald R. Nash’s conviction for the 1982 murder of Judy Spencer. The court held that Nash could be prosecuted under the pre-1984 capital-murder statute, that the evidence—including DNA found under the victim’s fingernails—was sufficient, and that the trial court was not required to give the former circumstantial-evidence instruction. The opinion also addresses the admissibility of evidence concerning third-person guilt under Missouri’s direct-connection rule.

Holdings

1. Nash's prosecution under section 565.001, RSMo 1978, was proper. The 1983 statutory changes did not decriminalize murders committed before the effective date of the new chapter 565, and the applicable law for the 1982 offense permitted prosecution under the law existing when the offense occurred.
2. The evidence was sufficient for a rational juror to find Nash guilty beyond a reasonable doubt.
3. The trial court did not commit reversible error by refusing to give the pre-1982 circumstantial-evidence instruction. The reasonable-doubt instruction accurately stated the State's burden, and the abandoned circumstantial-evidence instruction stated the same standard and would have been confusing and redundant.
4. The direct-connection rule is constitutional because it serves legitimate interests in preventing confusion and reducing the risk of misleading the jury. The trial court properly excluded evidence concerning Feldman because it did not directly connect him to Spencer's murder and consisted of remote or speculative circumstances.

Questions Presented

1. Whether Nash could be prosecuted under section 565.001, RSMo 1978, for a murder committed in 1982 even though that statute was repealed in 1983 and the prosecution commenced later.
2. Whether the evidence, including DNA evidence and other circumstantial evidence, was sufficient to support Nash's murder conviction.
3. Whether refusing to give the pre-1982 circumstantial-evidence jury instruction violated Nash's rights or otherwise constituted reversible error.
4. Whether Missouri's direct-connection rule for evidence suggesting third-person guilt is constitutional.
5. Whether the trial court abused its discretion by excluding evidence that Anthony Lambert Feldman had motive and opportunity to commit the murder.

Disposition

affirmed