Missouri Court of Appeals, Western District / Date unavailable
State of Missouri vs. David Shawn Williams
David Shawn Williams, a surety recovery agent, appealed his convictions for unlawful use of a weapon and kidnapping in the third degree, which arose from an incident where he forcibly entered a home and apprehended a fugitive. Williams argued the trial court erred by not sua sponte instructing the jury on a statutory exemption for process servers and that there was insufficient evidence for kidnapping because the restraint was merely incidental to another offense. The appellate court affirmed, holding that Williams did not qualify for the process server exemption and that the "merely incidental" restriction does not apply to kidnapping in the third degree.