Missouri Court of Appeals, Western District / Jan 8, 2019
State of Missouri vs. Derrick R. Patrick
Derrick R. Patrick appealed his conviction for domestic assault in the third degree. He argued the circuit court erred by admitting a 911 recording without proper authentication and by admitting police body camera footage containing an irrelevant and prejudicial statement about a knife threat. The appellate court affirmed the admission of the 911 recording, finding sufficient circumstantial evidence of the caller's identity. However, the court reversed the conviction, concluding that the body camera footage was improperly admitted as it did not reasonably reference the charged crime, and without it, the remaining evidence was insufficient to prove the elements of domestic assault beyond a reasonable doubt.