Supreme Court of Missouri / Apr 2, 2019
State of Missouri, Respondent, vs. Danielle Ann Zuroweste, Appellant.
Danielle Ann Zuroweste appealed her conviction for possession of a controlled substance, arguing the circuit court erred by admitting a recorded statement she made because the State disclosed it only four days before trial. The Missouri Supreme Court affirmed the conviction, finding that while the State violated discovery rules by failing to timely disclose the recording, the circuit court did not abuse its discretion in admitting the evidence. The Court reasoned that the discovery violation did not warrant exclusion because Zuroweste did not request a continuance, which would have remedied any alleged prejudice, and thus no fundamental unfairness resulted.