Missouri Court of Appeals, Southern District / Aug 26, 2024
STATE OF MISSOURI, Plaintiff-Respondent v. JAMES L. LANCASTER, Defendant-Appellant
James L. Lancaster appealed his conviction for third-degree domestic assault, arguing the trial court erred by admitting only a portion of a home surveillance video, thereby violating the rule of completeness. The video admitted depicted the entire assault, while Lancaster sought to introduce a longer video to impeach the victim's credibility. The Southern District of the Missouri Court of Appeals affirmed the conviction, finding no error in the admission of the video. The court held that the rule of completeness did not apply because the additional video was not part of a greater whole related to the charged conduct, and was sought only for impeachment.