Missouri Court of Appeals, Eastern District / Dec 26, 2023
State of Missouri, Respondent, vs. Paul Bolton, Appellant.
Paul Bolton, an inmate, appealed his conviction for endangering a corrections employee, arguing the trial court erred by excluding medical records that would have supported his defense that he spit involuntarily due to an allergic reaction. The appellate court affirmed the conviction. It held that Bolton failed to establish the proper foundation for the medical records under Missouri's business records statute, thus failing to overcome their inadmissible hearsay status.