Wednesday, December 4, 2013

State v. Sibley case brief

State v. Sibley case brief summary
131 Mo. 519 & 132 Mo. 102 (1895)

Defendant appealed his conviction by the Mississippi Circuit Court (Missouri) for defiling, debauching, and carnally knowing a victim, female under the age of 18 years, who was alleged to have been confided to his care and protection, a violation of Mo. Rev. Stat. § 3487 (1889). The victim was the daughter of defendant's wife by a former husband.

The victim lived with defendant from the time that she was nine. She left the home when she was 16 and pregnant with defendant's child. The mother and defendant denied both denied that he had any improper relations with the victim.


  • On appeal, the court reversed defendant's conviction. 
  • The court found that the victim was confined to the care of defendant, under the meaning of the statute. 
  • Defendant married her mother and assumed control over the victim, clothing and providing for her and sending her to school while she continued as a member of the household. 
  • The trial court did not err in admitting letters from the mother to the daughter when they were written at defendant's request and he was aware of the contents of the letters. 
  • The trial court erred in admitting declarations made by defendant that were conjectural and prejudicial to defendant. 
  • The statements were inadmissible for corroborating the prosecuting witness when they were not part of the res gestae. 
  • Evidence of defendant's general character for chastity was inadmissible to impeach the character of a male witness. 
  • Evidence of the victim's acts of intercourse with other person was inadmissible.

The court reversed the conviction. The court remanded the cause to the trial court.

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