Missouri Court of Appeals, Eastern District / Mar 18, 2025
State of Missouri, Respondent, v. Deandre Wilkes, Appellant.
Deandre Wilkes appealed his convictions for voluntary manslaughter and armed criminal action, arguing the trial court erred by admitting evidence of uncharged crimes and irrelevant victim character evidence, and by limiting his testimony about a prior encounter with the victim. The appellate court affirmed the judgment, finding no abuse of discretion in denying a mistrial for a vague reference to prior bad acts, nor in admitting victim testimony where the defense opened the door. The court also found no plain error in limiting testimony about a prior encounter due to a lack of an offer of proof and facial irrelevance of the excluded details.