{"disclaimer":"This is a summary of public court records and is not legal advice. Missouri slip opinions may be modified or withdrawn; consult the official source.","party":{"slug":"frank-g-hawkins","displayName":"Frank G. Hawkins","totalCases":1},"cases":[{"caseId":"moappwd:wd81946:2020-04-14","opinionId":"53519695-0c79-58da-8997-6b04e6ff855c","slug":"state-of-missouri-v-frank-g-hawkins-d81946","caseName":"State of Missouri\nvs.\nFrank G. Hawkins","caseNumber":"WD81946","court":"moappwd","courtLabel":"Missouri Court of Appeals, Western District","decisionDate":"2020-04-14","year":2020,"display_summary":"Frank G. Hawkins appealed his conviction for first-degree sodomy, arguing the trial court erred by admitting the child victim's out-of-court statements. Hawkins contended that the victim's non-verbal testimony did not satisfy statutory requirements and violated his Sixth Amendment right to confrontation. The Missouri Court of Appeals, Western District, affirmed the conviction, holding that non-verbal responses constitute testimony under section 491.075 and that a reluctant witness is not unavailable. The court also found no Confrontation Clause violation because Hawkins had an opportunity for effective cross-examination.","primaryTopic":"criminal-procedure","topicSlugs":["criminal-procedure","evidence","appellate-procedure","standard-of-review"],"outcomeNorm":"affirmed","officialSourceUrl":"https://www.courts.mo.gov/file.jsp?id=154613","detailUrl":"https://ott.law/missouri-courts/opinions/state-of-missouri-v-frank-g-hawkins-d81946","relatedPracticeAreas":[{"slug":"criminal-law","label":"Criminal Law","href":"/practice-areas/criminal-law","score":38,"source":"tag","evidence":["tag: criminal-law","topic: criminal-procedure","text: state of missouri","text: conviction"],"url":"https://ott.law/practice-areas/criminal-law"},{"slug":"litigation","label":"Civil Litigation","href":"/practice-areas/litigation","score":12,"source":"topic","evidence":["topic: evidence","topic: appellate-procedure"],"url":"https://ott.law/practice-areas/litigation"}],"role":"respondent"}]}