Missouri Court of Appeals, Southern District / Jun 28, 2019
STATE OF MISSOURI, Plaintiff-Respondent vs. ROBERT EDWARD SMITH, Defendant-Appellant
Robert Edward Smith appealed his convictions for domestic assault, arguing the trial court abused its discretion by denying his motion to compel the victim's mental health records or conduct an in camera review. Smith contended these records were necessary to support his defense that the victim's injuries were self-inflicted. The appellate court affirmed the convictions, holding that the trial court did not abuse its discretion because Smith failed to make an adequate showing that the privileged records were material and favorable. However, the court remanded the case for the sole purpose of correcting a clerical error in the written judgment regarding the classification of one conviction.