Missouri Court of Appeals, Eastern District / Sep 14, 2021
State of Missouri, Respondent, vs. James C. Street, Appellant.
James C. Street appealed his conviction for third-degree assault, charged as a class D felony under Missouri's Hate Crime statute, § 557.035. Street argued there was insufficient evidence that he assaulted the victim because of his race, despite repeatedly using racial slurs before punching the victim. The Eastern District affirmed the conviction, finding that the evidence, including the defendant's racist statements made moments before the assault, was sufficient to prove racial motivation. The court rejected the argument that more evidence was required based on comparisons to other hate crime cases.