JEFFREY SCOTT KOWALSKI, Defendant- Missouri Cases

Jeffrey Scott Kowalski was convicted of criminal merchandising practices, deceptive business practices, identity theft, and attempted stealing by deceit. On appeal, Kowalski argued he was improperly denied the right to represent himself and challenged the sufficiency of the evidence for criminal merchandising practices. The Southern District affirmed his convictions for deceptive business practices, identity theft, and attempted stealing by deceit, finding no abuse of discretion in denying self-representation. However, the court reversed Kowalski's conviction for criminal merchandising practices, holding that the State failed to prove the misrepresentation was made "in connection with the sale of merchandise in trade or commerce."