Supreme Court says man can tell self-defense story at trial

A man convicted of taking part in a deadly robbery will get a new trial thanks to the Missouri Supreme Court — and this time, he’ll get to tell his side of the story.

The court on Dec. 21 said defendant Tyler Gates’ constitutional rights were violated when a judge barred him from relating anything involving self-defense, lest he run afoul of a state law that says that defense cannot be claimed by anyone who commits or tries to commit a forcible felony. 

Judge Mary R. Russell, writing for the unanimous court, said the U.S. Supreme Court “has emphasized the fundamental importance of a criminal defendant’s right to present a complete defense.”

“The circuit court’s rulings violated these fundamental constitutional principles by denying Gates the opportunity to refute the charges against him by presenting his explanation of what happened,” she wrote.

Gates was convicted of felony murder in the fatal shooting of Matthew Haylock. Prosecutors alleged that Gates and another man had planned to rob Haylock of his gun. After asking to see the weapon, Gates allegedly refused to return it, then shot Haylock as he lunged at him from the backseat, using another gun that he’d borrowed from the accomplice.

Gates alleges that he and his accomplice had called off the planned robbery, but when they arrived Haylock put the gun in Gates’ face and tried to rob him. Gates alleges that he shot Haylock to save himself.

Gates was charged with felony murder because Haylock’s death stemmed from Gates’ alleged crime. Missouri law says self-defense is an absolute defense to criminal prosecution, but it cannot be claimed by anyone who commits or tries to commit a forcible felony, including robbery. The Supreme Court ruled in 2018 in State v. Oates that a man who killed two people during a non-forcible felony drug deal was precluded from claiming self-defense when charged with felony murder.

Russell, however, said neither the precedent nor the statute required the trial court to stop Gates from telling his version of events entirely. Oates held that self-defense is an available justification when the criminal act being prosecuted is the defendant’s use of force, Russell wrote in a footnote. And the statute, she added, “does not prevent a criminal defendant from arguing he or she used physical force for a purpose other than committing the forcible felony for which the defendant is charged.” 

The case is State v. Gates, SC98847.