Stacey A. Lannert v. Patricia Jones, Superintendent of Chillicothe Correctional Center

Citation: 321 F.3d 747Docket: 01-3665

Court: Court of Appeals for the Eighth Circuit; April 24, 2003; Federal Appellate Court

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Stacey A. Lannert appeals the denial of her habeas corpus petition following her conviction for the murder of her father. The Eighth Circuit Court affirms the district court's judgment. At trial, evidence revealed that Lannert, then 18, lived with her father and younger sister after her parents' divorce. She alleged long-term sexual abuse by her father, who was also described as an alcoholic with a violent temper. Lannert had recently returned from living with her mother in Guam and expressed a desire to kill her father. 

Prior to the murder, she engaged in fraudulent activities using her father's financial accounts and discussed plans with a friend to kill him. She became aware of her father's significant financial assets, including a $100,000 certificate of deposit, and expressed intentions to benefit from his death. On the night before the murder, after a social outing, Lannert entered her home through a basement window, found a rifle, and decided to kill her father. She shot him first in the shoulder and, after a brief moment of hesitation, shot him again in the head, resulting in his death.

After committing murder, the Defendant exited through a basement window and spent the night with her sister at a motel. The next day, they took the murder weapon, a rifle, to Barnett for disposal, who subsequently sold it and informed the police. The Defendant then returned home, cleaned her car, and staged a scene to alert neighbors to the situation, leading to the discovery of the body and a call for emergency assistance.

The Defendant, Lannert, was charged with first-degree murder and related felonies. At trial, she claimed insanity and sought to introduce evidence of "battered spouse syndrome" to support a self-defense argument. The trial court initially excluded this evidence until self-defense was introduced but allowed Lannert to present evidence of her alleged abuse. Ultimately, the court denied a jury instruction on self-defense, reasoning that Lannert's testimony did not indicate an immediate fear of serious injury or death, as her father was asleep at the time of the shooting. Consequently, the jury convicted her of first-degree murder and armed criminal action, sentencing her to life imprisonment without parole.

Lannert appealed, arguing that the trial court erred in excluding the battered spouse syndrome evidence and refusing the self-defense jury instruction. The Missouri Court of Appeals determined that she failed to preserve the self-defense issue for appeal due to a lack of evidence and an offer of proof. Following state court exhaustion, Lannert filed a federal habeas corpus petition asserting six grounds for relief. The district court denied it but allowed an appeal on her claims related to due process and fair trial violations regarding the exclusion of battered spouse syndrome evidence and the self-defense instruction.

In reviewing the habeas petition under 28 U.S.C. 2254, federal courts grant relief only if state court decisions are contrary to or unreasonably applied established federal law or based on unreasonable factual determinations, with factual findings assessed for clear error and legal conclusions reviewed de novo.

The State argues that Lannert's failure to preserve her evidence-related claim for appeal constitutes an "independent and adequate state ground" that precludes federal habeas review, as supported by Ivy v. Caspari. A state court's dismissal of claims on such grounds typically bars federal review unless the petitioner shows cause for the default and actual prejudice. The district court, however, found that the Missouri appellate court's determination that Lannert failed to present evidence of self-defense indicated a merits review of her claim, thereby allowing federal consideration. It was established that procedural bars do not apply when a state court provides at least cursory consideration of the claims.

Lannert's first argument cites Hicks v. Oklahoma, asserting that Missouri's battered spouse syndrome statute represents a state-created right that was violated, thus infringing on her due process. However, the court clarified that its habeas review focuses on constitutional violations rather than mere state law breaches. Lannert's claim mirrors one previously rejected in Chambers v. Bowersox, where it was determined that the enforcement of state law does not automatically imply a violation of federal constitutional rights. The court concluded that Lannert's case does not fit within the narrow framework established by Hicks, and therefore, it declined to recognize her claim as a constitutional violation stemming from an alleged state law infringement.

Lannert's claim was not found to be reviewable under the Hicks standard, and the trial court's evidentiary ruling was upheld as consistent with Missouri law. Missouri's battered spouse syndrome statute requires that self-defense must already be a relevant issue for syndrome evidence to be admissible. The Missouri Supreme Court defines self-defense as a right to protect oneself against personal attacks, outlining that deadly force is justified only under specific conditions: absence of provocation, real necessity for lethal action to avoid serious harm, reasonable belief in that necessity, and an effort to avoid conflict. The Court of Appeals has indicated that battered spouse syndrome can influence the mental state of the battered individual, making self-defense elements more applicable to them. However, the district court concluded that the evidence showed Lannert was the initial aggressor when she shot her father, who was incapacitated at the time, and noted there was no indication of immediate threat or prior abuse on that night. Consequently, the court determined that the elements of self-defense were not satisfied, justifying the exclusion of expert testimony on battered spouse syndrome. The analysis aligns with precedent indicating self-defense is not applicable when the defendant instigates the confrontation.

Lannert asserts that her father, who raped her as a child, was the initial aggressor and thus responsible for her situation. However, this claim lacks support in Missouri law, which maintains that determinations made by the Missouri Court of Appeals are binding. The district court noted potential policy reasons for easing evidentiary thresholds related to battered spouse/child syndrome, yet any changes must be addressed by the Missouri Legislature and courts, not mandated by federal law. Consequently, Lannert's argument that the trial court erred in excluding expert testimony on battered spouse syndrome under Missouri Code section 563.033 is rejected.

Furthermore, Lannert contends that the exclusion of this evidence constituted an independent constitutional violation, infringing on her right to a fair trial and complete defense. The Supreme Court acknowledges a constitutional guarantee for defendants to present a complete defense, but this right has limitations. A defendant cannot introduce evidence that is incompetent or inadmissible under standard rules. Thus, Lannert faces a significant burden to prove that her right to present evidence of battered spouse syndrome in relation to a self-defense claim is a fundamental principle of justice, as outlined in relevant case law.

Lannert did not meet the burden of proof regarding her due process claims, failing to provide relevant arguments or authority on the due process inquiry. She emphasized her right to present favorable evidence while neglecting the limitations on that right. Consequently, the exclusion of expert testimony on battered spouse syndrome did not constitute a violation of clearly established federal law under 28 U.S.C. 2254(d)(1). Additionally, her claims regarding expert testimony on blood spatter and psychological evidence failed to assert federal constitutional claims. 

Regarding self-defense, Lannert argued the trial court improperly denied her request for a jury instruction on self-defense, asserting this violated her due process rights under the Fourteenth Amendment. The court acknowledged that a defendant is entitled to such an instruction if supported by evidence, as established in relevant case law. The right to assert self-defense is deemed fundamental, and failure to instruct the jury on this could infringe upon a defendant's Fifth and Sixth Amendment rights. However, mere evidentiary support for self-defense does not alone warrant habeas relief; the refusal to instruct must also be of a constitutional nature, indicating a fundamental defect or a miscarriage of justice.

Lannert was denied a self-defense instruction under Missouri law because she was deemed the initial aggressor in the altercation. This conclusion aligns with precedents such as *State v. Nunn*, where a self-defense claim was rejected under similar circumstances. The court found no violation of constitutional rights due to the absence of this instruction and was unpersuaded by Lannert's challenges to Missouri's self-defense interpretation. The court emphasized deference to state legislative decisions in criminal matters, affirming that Lannert's failure-to-instruct claim did not warrant habeas relief. The judgment was ultimately affirmed. Additionally, the concurring opinion noted that while the Missouri Court of Appeals narrowly construed the battered spouse syndrome statute, there were reasonable grounds to argue that Lannert's father was the true initial aggressor, especially considering the history of abuse. However, the state courts maintained that without the self-defense instruction, Lannert could not present evidence of battered women’s syndrome to support her claim.

Missouri's battered spouse syndrome statute is critical for modifying the mental state requirement for women who are victims of prolonged abuse. The Missouri Court of Appeals in *Williams* established that this syndrome influences a battered woman's perception, allowing her to meet the elements of self-defense. In *Edwards*, the court clarified that if a jury believes a defendant suffers from this syndrome, they must evaluate her actions through the lens of how someone in her situation would perceive and react to ongoing abuse. However, Missouri courts have ruled that the syndrome cannot serve as a standalone defense to murder; it is only admissible as evidence of a battered woman’s state of mind to support a self-defense claim. This requires the woman to present a credible self-defense theory before disclosing the impact of her abuse, which limits the statute's intended purpose by enforcing traditional self-defense criteria. Additionally, the lack of clarity in the self-defense statute regarding the timing of aggression and response is concerning, as it suggests that the jury may not have been fully informed of the extent of the abuse suffered by the defendant, Lannert. This omission could have influenced the jury's understanding of whether she was the initial aggressor, potentially affecting the case's outcome. Despite these concerns, the authority of Missouri courts to interpret the battered spouse syndrome statute is acknowledged.