# State v. Chaney

> Supreme Court of Missouri · March 24, 1998 · 967 S.W.2d 47

URL: https://www.frixlaw.com/law-library/cases/9772275

## Case

- **Full name:** STATE of Missouri, Respondent, v. Timothy S. CHANEY, Appellant
- **Court:** Supreme Court of Missouri
- **Decided:** March 24, 1998
- **Citations:** 967 S.W.2d 47; 1998 Mo. LEXIS 29; 1998 WL 130831
- **Precedential status:** Published
- **Opinion:** Dissent by White
- **Judges:** Holstein, Price, Limbaugh, White, Robertson, Covington
- **Cited by:** 267 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/9772275

## How later opinions describe it (automated extraction)

- holding that "[b]ecause the equally valid inferences rule is at war with the due process standard governing an appellate court’s review of the sufficiency of evidence, the equally valid inferences rule should no longer be applied”
- stating that evidence of a known pedophile living in the area where the young victim went missing and the pedophile's lies to police about his whereabouts during the relevant time did not directly connect him to the charged murder
- recognizing that the “equally valid inferences” rule was abolished by Grim, 854 S.W.2d at 413-14
- holding that "[t]he equally valid inferences rule was effectively abolished"

## Opinion text

WHITE, Judge,
dissenting.
I respectfully dissent. Michelle Winter suffered a violent and senseless death. The tragic circumstances of her death, however, do not relieve the State of its burden of proving that it was the defendant that caused her death beyond a reasonable doubt. As the principal opinion states, this Court is not to act as a “super juror” and veto the jury’s verdict based on a reweighing of the evidence. 1 To affirm a conviction, however, this Court must do more than compose a scenario wherein the jury could find the defendant guilty. The fact that we are reviewing a conviction demonstrates that such a scenario exists. For a review of the sufficiency of the evidence to have a purpose beyond rubber-stamping convictions, this Court must do more than merely pay lip service to the standard of “beyond a reasonable doubt.”
A reasonable juror must be able to infer from the State’s evidence that Timothy Chaney knowingly caused Michelle Winter’s death after deliberation on the matter. 2
An ‘inference’ is a conclusion drawn by reason from facts established by proof; ‘a deduction or conclusion from facts or propositions known to be true.’ ... A supposition is a conjecture based on the possibility that a thing could have happened. It is an idea or a notion founded on the probability that a thing may have occurred, but without proof that it did occur. 3
The strength of the inferences must be such that a reasonable juror could be convinced of guilt beyond a reasonable doubt. Proof beyond a reasonable doubt is “proof that leaves you firmly convinced of the defendant’s guilt.” 4
The State presented evidence that Michelle and Stephanie spent time together at the Chaney house on the afternoon of April 8, 1995. Timothy Chaney left the house in his van between 4:30 and 5:00 p.m. Michelle left on foot at 4:50 p.m. Neighbors saw Michelle walking in the direction of her house at 5:00 p.m. Michelle’s mother called Stephanie around 6:00 p.m., inquiring after Michelle. Timothy Chaney consistently stated that Michelle had not been in his van in the past year. He gave varying accounts of his whereabouts between 5:00 and 9:00 p.m. on the evening in question. When Michelle’s body was found, the combination of particles clinging to her clothes matched materials found in the back of Timothy Chaney’s van. From this evidence, a reasonable juror could infer that Michelle was in Timothy Chaney’s van at some point on April 8, 1995, and that he had the opportunity to kill her.
The scenario proposed by the principal opinion consists of conjecture, stacking overlapping probabilities until it can link Timothy Chaney with the hand that inflicted the fatal stab wounds. The principal opinion even stacks suppositions on the absence of evidence, concluding, from the absence of testimony that anyone in the neighborhood heard Michelle scream or any other unusual noises, that Michelle disappeared into a vehicle, and disappeared into a vehicle of someone that she knew. While this is a possible explanation, it is not a logical inference of fact.
On top of the inference of opportunity and the speculation that Michelle entered a vehicle of someone that she knew, the principal opinion adds the facts that Chaney had on occasion gone camping and fishing in the Cape Fair area and that he had owned a business in a nearby community. The principal opinion concludes that these facts “connected Chaney to the murder.” 5 Again, *62 such a conclusion is based on conjecture, not logical inference.
Once these suppositions are discarded, adding “consciousness of guilt” evidence 6 to the inference that Timothy Chaney had the opportunity to kill Michelle proves that he was conscious that he had a weak alibi. While it pains me to advocate reversing the conviction of a defendant who might be a murderer, 7 “might be” is not the applicable standard of review.
On the other hand, I am fully aware that the outcome of this appeal does not hinge on whether or not I would have reached a different verdict had I sat in the jury box. The standard is whether a reasonable juror following the trial court’s instructions could be firmly convinced, based only on the State’s evidence and logical inferences therefrom, without filling any gaps with gut instinct, that Timothy Chaney committed first-degree murder. After careful analysis of all the evidence, disregarding all inferences contrary to the State’s case, it is clear that the State’s case against Chaney is missing an essential element. No evidence ties him to the crime either directly or by first generation inference.
The principal opinion insists that a reversal in this case would create a burden on the State to affirmatively “disprove every reasonable hypothesis except that of guilt.” 8 I disagree. A reversal of Timothy Chaney’s conviction would not change the law that the State may secure a conviction on circumstantial evidence that is subject to conflicting inferences. It is the principal opinion that creates new law — lessening the State’s burden — by extending this Court’s review of the evidence in the light most favorable to the verdict to include the discretion to resolve any conceivable supposition in the State’s favor. I understand this is the only way to rescue the State and affirm Timothy Chaney’s conviction, but I am not prepared to take this step at the expense of future defendants. A reversal in this case is the only way to enforce the existing burden on the State, as imposed by the guarantees of due process, to prove each element of a crime beyond a reasonable doubt. 9
I would reverse Timothy Chaney’s conviction for insufficient evidence. Therefore, I do not concur with the principal opinion with regard to the conviction or the sentence.
. Op. at 53.
. MAI-CR 3d 302.01.
. Draper v. Louisville & N.R. Co., 348 Mo. 886 , 156 S.W.2d 626, 630 (1941) (emphasis added citations omitted). See State v. Foster, 930 S.W.2d 62 (Mo.App.1996). See also State v. Grim, 854 S.W.2d 403, 420 (Mo. banc 1993) (Robertson, J., dissenting).
. MAI-CR 302.04.
. Op. at 54.
. Id. at 54-55.
. When a conviction is overturned on the grounds that the evidence at trial was insufficient to support a finding of guilt, the double jeopardy clause prohibits the defendant from being retried for the same crime. U.S. Const, amend. V (as made applicable to proceedings in state courts through the Fourteenth Amendment by Benton v. Maryland, 395 U.S. 784 , 89 S.Ct. 2056 , 23 L.Ed.2d 707 (1969). State v. O'Brien, 857 S.W.2d 212, 221 (Mo. banc 1993)); See Hudson v. Louisiana, 450 U.S. 40 , 101 S.Ct. 970 , 67 L.Ed.2d 30 (1981); Burks v. United States, 437 U.S. 1 , 98 S.Ct. 2141 , 57 L.Ed.2d 1 (1978).
. Op. at 55.
. See In re Winship, 397 U.S. 358, 364 , 90 S.Ct. 1068, 1072-73 , 25 L.Ed.2d 368 (1970).

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/9772275. Public record. Not legal advice.