Missouri Court of Appeals, Western District / Feb 2, 2021
State of Missouri vs. Deion D'Wayne Crum
Deion D'Wayne Crum appealed his conviction for possession of a controlled substance, arguing the trial court erred in denying his motion to suppress evidence obtained during a warrantless search of his apartment. The appellate court found that the trial court improperly placed the burden of proof on Crum to show that consent to search was involuntary, rather than requiring the State to prove voluntary consent. Additionally, the trial court failed to make necessary factual determinations regarding the voluntariness of consent. The judgment was reversed, and the case remanded for reconsideration with the burden of proof correctly placed on the State.