Missouri’s Western District Court of Appeals held that the admission of evidence of “drugs and drug paraphernalia” was inadmissible in a robbery trial, without corroborating evidence of drug habit or addiction. The State argued that the drug evidence was admissible as evidence of motive. The Court, however, noted that the record lacked any specific evidence connecting drug use to the offense charged:
“While it is true that evidence of prior drug use may be admissible to explain the defendant’s motive to steal to support a drug habit, the state is not automatically entitled to assume that whenever a defendant is charged with the crime of stealing, evidence of other crimes bearing on motive is automatically admissible.”
View The Missouri Criminal Defense Law Opinion: State v. Johnny L. Allen
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