Missouri Court of Appeals, Eastern District / Feb 13, 2024
State of Missouri, Respondent, vs. Christopher L. Gates, Appellant.
Christopher L. Gates appealed his convictions for first-degree murder, armed criminal action, and resisting arrest, following a bench trial. He challenged the trial court's admission of his custodial interrogation recording, arguing his Miranda waiver was unknowing, involuntary, and unintelligent, and also contested the admission of an audio recording from the victim's phone due to an alleged lack of foundation. The Missouri Court of Appeals, Eastern District, affirmed the judgment, concluding that Gates knowingly and intelligently waived his Miranda rights and that the State established a proper foundation for the audio recording.