Missouri Court of Appeals, Southern District / Jan 11, 2024
STATE OF MISSOURI, Plaintiff-Respondent vs. MICHAEL MOORE, Defendant-Appellant
Michael Moore appealed his convictions for statutory rape and statutory sodomy, arguing the trial court erred by excluding the victim's first forensic interview. Moore contended the recording was admissible under a statute, to show the victim's demeanor, or under the rule of completeness. The appellate court affirmed the judgment, declining plain error review for the statutory and completeness arguments due to lack of preservation. The court found no abuse of discretion in excluding the full interview for demeanor evidence, as Moore had sufficient opportunity to impeach the victim's credibility through other means.