Missouri Court of Appeals, Southern District / Jul 18, 2024
STATE OF MISSOURI, Plaintiff-Respondent v. RYAN ROBERT HOUSTON, Defendant-Appellant
Ryan Houston appealed his conviction for second-degree assault against a special victim, arguing the State failed to prove he knew the victim was an elderly person. The appellate court affirmed the conviction. The court held that the relevant statute, § 565.052.3, does not require proof of a defendant's knowledge of a victim's special status because § 562.021.2 dictates that a culpable mental state is only required for elements explicitly specified in the offense definition.