Missouri Court of Appeals, Southern District / Aug 28, 2024
STATE OF MISSOURI, Respondent v. TIMOTHY LOUIS SMITH, Appellant
Timothy Louis Smith called 911 for a medical emergency, and after EMS cleared him, he asked a law enforcement officer for a ride. The officer agreed on the condition of a consent search, which revealed methamphetamine residue and a syringe cap. Smith was convicted of drug offenses, but argued on appeal that he was immune under Missouri's Good Samaritan Law, section 195.205, because the evidence was found "as a result of" his call for medical assistance. The appellate court affirmed the conviction, holding that the statute requires a stronger causal connection than "but for" causation, and the evidence was found due to his consent to search, not directly from seeking medical assistance.