State v. Laughlin

• Docket Number: EDI 10894
• Decision Date: 07 November 2023
• Parties: STATE OF MISSOURI, Respondent, v. RICKY L. LAUGHLIN, Appellant.
• Court: Court of Appeal of Missouri (US)

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STATE OF MISSOURI, Respondent,
v.
RICKY L. LAUGHLIN, Appellant.

No. EDI 10894

Court of Appeals of Missouri, Eastern District, Second Division

November 7, 2023

Appeal from the Circuit Court of St. Francois County Honorable Brice R. Sechrest

KURT S. ODENWALD, Presiding Judge

Introduction

Ricky L. Laughlin ("Laughlin") appeals from his convictions following a bench trial on operating a motor vehicle in a careless and imprudent manner involving an accident and driving while his license was revoked after Laughlin was found lying on the ground outside of the driver's side of his crashed truck. Laughlin challenges his convictions by arguing that there was insufficient evidence from which a rational factfinder could determine that he was operating the truck at the time of the crash, which was an essential element for both offenses. Because the State presented evidence from which a rational factfinder reasonably could infer that Laughlin was operating the truck at the time of the crash, we deny Points One and Two. Accordingly, we affirm the trial court's judgment.

Factual and Procedural History

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Laughlin waived his right to a jury trial and proceeded to a bench trial at which he testified in his own defense. Viewed in the light most favorable to the verdict,^[1] the following evidence was adduced at trial:

Laughlin and E.L. were both found at the scene of an accident where Laughlin's pickup truck crashed into a tree. A Missouri State Highway Patrol Trooper ("Trooper"), the responding officer, testified as the State's sole witness. The Trooper determined the truck crashed because Laughlin failed to negotiate a curve in the road, overcorrected, crossed back over the road, then crashed into a tree. When the Trooper arrived at the scene, he found Laughlin lying on the ground directly in front of the truck, which had a large hole in the front windshield on the driver's side. Laughlin had cuts on his face and was being treated by EMS when the Trooper arrived. E.L. was lying on the ground outside the truck's open passenger door and was also being treated by EMS. The passenger-side windshield was also damaged but was not broken.

There was no eyewitness testimony indicating who was driving at the time of the crash. Neither Laughlin nor E.L. admitted to driving the truck. The Trooper stated he "couldn't get them to speak enough at the time because they just couldn't talk . . . [t]hey were injured." The Trooper determined Laughlin was driving the truck when it crashed because he was lying directly in front of the truck with cuts on his face consistent with going through the front windshield. Contrastingly, E.L. was lying on the ground outside the open passenger door and there was no hole in the passenger side of the windshield. The Trooper testified that he did not know if EMS had moved Laughlin after they arrived on the scene or if Laughlin or E.L. had moved on their own prior to EMS arriving.

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The Trooper checked the status of Laughlin's driver's license and the truck's registration. Records indicated that Laughlin's driver's license was suspended and that the license plates on the truck were registered to another one of Laughlin's vehicles.

Laughlin denied driving the truck. Laughlin testified that E.L. drove off in the truck while he was in the truck bed and that E.L. was unaware he was in the truck bed. Laughlin further testified that he stuck his head in the driver's side window, which frightened E.L. and caused her to drive off the road into the tree. A hearsay statement from an unidentified person on the Trooper's audio recording supported Laughlin's testimony.

The trial court found Laughlin guilty of operating a motor vehicle in a careless and imprudent manner involving an accident; driving while his license was revoked; failing to register a motor vehicle; and failing to wear a properly adjusted or fastened seat belt.^[2] The trial court sentenced Laughlin to sixty days in jail for careless and imprudent driving and suspended the execution of the sentence, placing Laughlin on probation for two years. Laughlin also received fines totaling $310 for the remaining offenses. This appeal follows.

Points on Appeal

In his two points on appeal, Laughlin contends the trial court erred in overruling his motion for a judgment of acquittal and in sentencing Laughlin for careless and imprudent driving and driving while his license was revoked because there was insufficient evidence from which a rational factfinder could determine he was guilty. Specifically, the State failed to prove beyond a reasonable doubt that he was operating the truck at the time of the crash.

Standard of Review

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In reviewing whether sufficient evidence supports a conviction "to withstand a motion for judgment of acquittal, this Court does not weigh the evidence but rather accepts as true all evidence tending to prove guilt together with all reasonable inferences that support the verdict, and ignores all contrary evidences and inferences." State v. Lehman, 617 S.W.3d 843, 846-47 (Mo. banc 2021) (quoting State v. Gilmore, 537 S.W.3d 342, 344 (Mo. banc 2018)). "When reviewing the sufficiency of the evidence, the standard of review on appeal from a bench-tried case is the same as the standard used on appeal of a case tried to a jury." State v. Summers, 653 S.W.3d 155, 166 (Mo. App. W.D. 2022) (citing State v. Morris, 640 S.W.3d 762, 765 (Mo. App. W.D. 2022)).

"Circumstantial rather than direct evidence of a fact is sufficient to support a verdict." Lehman. 617 S.W.3d at 847 (internal citation omitted). "If that evidence supports equally valid inferences, it is up to the factfinder to determine which inference to believe, as' [t]he [factfinder] is permitted to draw such reasonable inferences from the evidence as the evidence will permit.'" Id. (alterations in original) (internal quotation omitted). Although we may rely on circumstantial evidence, we will not "supply missing evidence or give the state the benefit of unreasonable, speculative or forced inferences." Id. (internal quotation omitted). We ask "only whether there was sufficient evidence from which the trier of fact reasonably could have found the defendant guilty." Id. (internal quotation omitted).

Discussion

For both driving-related offenses challenged on appeal, the State was required to prove beyond a reasonable doubt that Laughlin was operating the truck at the time of the crash. See id. (citing State v. Seeler, 316 S.W.3d 920, 925 (Mo. banc 2010)) ("The State must prove every element of a crime charged beyond a reasonable doubt."). Laughlin alleges that there was insufficient evidence from which a rational factfinder could find that he was the driver.

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Under Section 304.012,^[3] a person "operating a motor vehicle on the roads and highways of this state shall drive the vehicle in a careful and prudent manner .. . and shall exercise the highest degree of care." If a person operates a motor vehicle in a careless and imprudent manner resulting in an accident, it is a class A misdemeanor. Section 304.012. Relatedly, Section 302.321 prohibits "operat[ing] a motor vehicle on a highway when such person's license...