Missouri Court of Appeals, Eastern District / Jul 8, 2025
State of Missouri, Respondent, vs. Christopher L. Bolden, Appellant.
Christopher Bolden appealed his convictions for second-degree murder and other charges, arguing the trial court plainly erred by not sua sponte instructing the jury on defense of others. Bolden claimed he shot the victim because the victim was choking his ex-girlfriend, but later recanted this story. The Eastern District of the Missouri Court of Appeals disagreed, declining to conduct plain error review because Bolden recanted the only evidence supporting a defense-of-others instruction. The court affirmed the judgment of the trial court.