Stacey A. Lannert v. Patricia Jones

Citation: Not availableDocket: 01-3665

Court: Court of Appeals for the Eighth Circuit; March 10, 2003; Federal Appellate Court

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Stacey A. Lannert appeals the denial of her habeas corpus petition by the district court. The Eighth Circuit Court of Appeals affirms this judgment. At trial, the Missouri Court of Appeals presented evidence indicating that Lannert, then 18, lived with her father, Tom Lannert, and her 14-year-old sister. Following her parents' divorce, she and her sister alternated living with their mother, who resided in Guam, and their father. Lannert alleged ongoing sexual abuse by her father since third grade and described him as an alcoholic with a violent temper. After returning from Guam, she expressed a desire to kill her father and discussed plans with a friend, including how to make it appear as a burglary. Lannert practiced shooting a rifle at her grandparents' home and engaged in fraudulent activities involving her father’s credit cards and bank accounts, using the illicit funds for personal purchases and to pay her friend Barnett’s rent. Days prior to the murder, she mentioned to a friend, Jason Fortune, that her father's death would be financially beneficial due to a significant estate, including a $100,000 certificate of deposit. On the night before the murder, after a social outing, Lannert entered her home through a basement window, found the rifle, and decided to kill her father. She shot him first in the shoulder, waking him, then, after deliberating, shot him point-blank in the head, resulting in his death, before fleeing through the same basement window.

Lannert and her sister spent the night at a motel, after which she took a rifle to Barnett for disposal; he sold it to a friend and later informed the police. The following day, Lannert and Fortune created a scene to mislead neighbors, prompting a neighbor to discover a body and call for emergency assistance. Charged with first-degree murder, Lannert asserted a defense of mental disease or defect and sought to introduce evidence of "battered spouse syndrome" under Missouri law, arguing it was relevant to self-defense. The trial court excluded mention of the syndrome until self-defense was raised but allowed an offer of proof regarding her alleged abuse. Ultimately, the court denied a self-defense jury instruction, reasoning that Lannert's testimony did not indicate an immediate fear of harm, as her father was intoxicated and asleep when she fired the shot. The jury convicted her of first-degree murder and armed criminal action, sentencing her to life imprisonment without parole.

On appeal, Lannert contended the trial court erred by excluding battered spouse syndrome evidence and refusing a self-defense instruction. The Missouri Court of Appeals held that the first issue was not preserved for appeal due to a lack of evidence presented by Lannert. Consequently, it also rejected her self-defense claim. Following state court exhaustion, Lannert sought habeas corpus relief under 28 U.S.C. 2254, asserting violations of her Fifth, Sixth, and Fourteenth Amendment rights due to the exclusion of evidence and the denial of a self-defense instruction. The district court denied her petition but allowed an appeal regarding the due process and fair trial claims. Federal habeas relief under 2254 is limited to cases where state court decisions contradict or unreasonably apply established federal law or are based on unreasonable factual determinations.

Reviewing a denial of a 2254 habeas petition involves assessing the district court's factual findings for clear error and legal conclusions de novo. The State contends that Lannert's failure to preserve her evidence-related claim for appeal creates an independent and adequate state ground that precludes federal habeas review. Federal courts cannot review claims dismissed by state courts on such grounds unless the petitioner shows cause and actual prejudice from the federal violations. The district court disagreed, finding that the Missouri appellate court's conclusion regarding the lack of evidence for self-defense indicated a merits review of the claim, which does not trigger procedural default barriers.

Lannert's argument hinges on the Supreme Court's ruling in Hicks v. Oklahoma, asserting that Missouri's battered spouse syndrome statute creates a state-guaranteed due process right. She argues that the trial court's exclusion of her expert testimony violated this right. However, federal habeas review is confined to constitutional issues, and mere violations of state law do not equate to federal constitutional violations. The court draws parallels to prior rulings that rejected similar arguments, asserting that Lannert's case does not meet the narrow parameters established in Hicks. Additionally, even if her claim were examined under Hicks, the court finds no error in the trial court's evidentiary ruling, noting that the Missouri statute requires self-defense to be an issue for syndrome evidence to be admissible.

The Missouri Supreme Court defines self-defense as the privilege to protect oneself from personal attack, requiring specific conditions to justify the use of deadly force. These conditions include: (1) the defender must not have been the initial aggressor, (2) there must be a genuine necessity to use deadly force to prevent serious bodily harm or death, (3) the defender's belief in this necessity must be reasonable, and (4) the defender must have attempted to avoid the danger if possible. 

The court acknowledged that battered spouse syndrome can influence the mental state of the battered individual, potentially affecting the perception of self-defense elements. However, the district court concluded that this statute does not negate the requirement that the defendant must not have been the initial aggressor. In Lannert's case, evidence showed that she shot her father while he was unconscious, and there was no immediate threat or aggression from him at that moment. Therefore, the court ruled that she met the definition of the initial aggressor, leading to the exclusion of expert testimony on battered spouse syndrome as it was not relevant to her defense.

The court also noted that while there may be policy reasons to modify the evidentiary standards regarding battered spouse syndrome, such changes would be up to the Missouri Legislature and courts, not mandated by federal law. Lannert's argument that the exclusion of evidence constituted a constitutional violation was rejected, as the Supreme Court has established that the right to present a complete defense is not absolute. Lannert bore the burden of proving a due process violation but failed to provide sufficient argument or authority to support her claim regarding the fundamental importance of the evidence she sought to introduce.

The defendant argues for the right to present evidence favorable to her case, specifically regarding expert testimony on battered spouse syndrome and blood spatter analysis. However, the court finds that the exclusion of such testimony does not constitute a violation of federal law as established by the Supreme Court. Claims of due process violations related to the exclusion of psychological testimony are deemed insufficient to establish federal constitutional claims.

Regarding self-defense, the defendant contends that the trial court's refusal to instruct the jury on self-defense violates her due process rights. While acknowledging that a defendant has the right to a self-defense instruction when sufficient evidence exists, the court determines that the failure to provide this instruction does not amount to a constitutional violation under Missouri law. Even though evidence supported the self-defense claim, the court concludes that the Missouri courts correctly ruled the defendant as the initial aggressor, negating her entitlement to such an instruction.

The court affirms the judgment, with a concurring opinion noting that while the interpretation of the battered spouse syndrome statute is binding, the narrow interpretation applied by the Missouri Court of Appeals may not be warranted. Ultimately, the defendant's claims regarding the lack of a self-defense instruction do not merit habeas relief.

Lannert and her sister experienced years of sexual abuse by their father, leading to the conclusion that he was the initial aggressor. Lannert's altered state of mind, shaped by this abuse, caused her to fear further harm from him, particularly on the night of his death. The Missouri battered spouse syndrome statute is discussed as a means to modify the mental state required for self-defense claims. The Williams court emphasized that the syndrome influences how a battered woman perceives her situation, suggesting that juries should consider her perspective in light of prolonged abuse. The Missouri Court of Appeals in State v. Edwards indicated that if a jury acknowledges a defendant's battered spouse syndrome, they must evaluate her actions based on what a reasonable person in her position would perceive. However, the courts have ruled that while the syndrome can inform a defendant's state of mind, it cannot be used as a direct defense against murder. A viable self-defense theory is necessary for a battered woman to present evidence of the syndrome. This requirement limits the statute's effectiveness by enforcing traditional self-defense principles. The lack of comprehensive information about Lannert's abuse and emotional state hindered the jury's understanding, potentially affecting the trial's outcome. The author expresses concern that the jury was not fully informed about the context of Lannert’s actions and her fears for her sister, which could have led to a different verdict. Despite these concerns, the author acknowledges the authority of Missouri courts to interpret the relevant statute.