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Conflicting testimony from a single State witness does not defeat sufficiency of conviction

In a 6-1 opinion, the Court affirmed judgment for the State upholding the statutory rape conviction against the defendant, finding a reasonable juror could conclude beyond a reasonable doubt that the defendant had sexual intercourse with the victim when she was less than 14 years old. While the victim simultaneously testified at trial that she was 14 when the offense occurred and that she was a preteen when the defendant had intercourse with her, the Court held that because the victim’s testimony that she was 14 was contrary to the verdict, the testimony must be disregarded. In making its decision, the Court noted in a footnote that the equally valid inference rule, which states that guilt beyond a reasonable doubt cannot be established where two equally valid inferences can be drawn from the same evidence, has been effectively abolished. As such, the Court found sufficient evidence for the jury to conclude that the victim was a preteen, and thus less than 14 years old based on the dictionary definition of “preteen,” during the charged conduct.

The dissent would have remanded for a new trial on the lesser offense of second-degree statutory rape on the grounds that the State failed to satisfy its burden to demonstrate that the alleged conduct occurred within the specific date range alleged in the jury instructions. The dissent highlighted that the State only presented evidence that the victim was a preteen, which broadens the timeframe in which the alleged conduct could have occurred beyond the date range specified in the jury instructions, and that the State could have taken measures to ensure the evidence presented at trial conformed with the requirements of the elements of the offense as charged in the jury instructions.

SC101373 State v. Guthrie