Tyler J. Gates Missouri Cases

Tyler J. Gates appealed his conviction for second-degree felony murder and armed criminal action, stemming from a shooting where he claimed self-defense during an attempted robbery. The circuit court repeatedly denied Gates's attempts to present evidence of self-defense, preventing him from offering his own version of events to counter the underlying robbery charge. The Missouri Supreme Court reversed the judgment and remanded the case, holding that the circuit court's evidentiary rulings infringed on Gates's Sixth and Fourteenth Amendment rights to present a complete defense.

Tyler J. Gates appealed his convictions for felony murder in the second degree and armed criminal action, arguing the trial court infringed on his right to testify by excluding self-defense testimony, plainly erred by not instructing the jury on self-defense, and failed to strike a venireperson sua sponte. The appellate court affirmed, holding that self-defense is not a legally available defense to felony murder predicated on a forcible felony. The court also found Gates's evidentiary claims unpreserved or not plainly erroneous, and no plain error in the jury selection.