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Criminal Law-Murder-Hearsay Testimony
Staff Report//April 22, 2026//
Defendant appealed his conviction for murder and armed criminal action, arguing that the trial court abused its discretion in admitting police testimony about ShotSpotter data because it contained hearsay and constituted improper expert testimony. Defendant further argued that the admitted surveillance video and still frames violate the rule of completeness and the best evidence rule because it only constituted a portion of the video and was made from a recording of the original surveillance video.
Where the ShotSpotter data was computer-generated, there was no hearsay violation, and there was no “greater whole” that the video exhibit’s clips were apart and thus no violation of the rule of completeness.
Judgment is affirmed.
State v. Griffin-Curry (MLW No. 84641/Case No. ED113192 – 16 pages) (Missouri Court of Appeals, Eastern District, Wright, J.) Appealed from circuit court, City of St. Louis, Boyer, J. (Gwenda R. Robinson for appellant) (Wensdai Brooks for respondent)
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