## Facts

- William Rieken operated a roadside produce stand at his home near Kansas City, Missouri.
- Late on August 19, 1950, an armed intruder entered Rieken’s bedroom, demanded money, and used a flashlight that allowed Rieken to see him.
- Rieken retrieved and surrendered $325; the intruder threatened to shoot if Rieken left the room, then fled with others in a vehicle.
- Rieken later identified St. Clair as the intruder.
- On August 26, 1950, police arrested St. Clair along with two alleged accomplices at St. Clair’s home; officers found a stolen automobile, multiple firearms, flashlights, and ammunition.
- St. Clair admitted participating in the robbery but claimed he acted under coercion by the accomplices.
- St. Clair presented evidence of mental impairment, limited schooling, and prior commitments to a state hospital as an insane person.
- At trial, St. Clair pleaded not guilty by reason of insanity and duress; the court instructed on insanity but refused a requested instruction on duress.

## Issues

1. Whether the trial court erred by refusing to instruct the jury on duress where the defendant admitted the robbery but claimed coercion by accomplices.
2. Whether asserted evidentiary errors required reversal.
3. Whether denial of a mistrial based on allegedly improper prosecutorial argument was reversible error.

## Decision

- The Supreme Court of Missouri affirmed the conviction and five-year sentence for first-degree robbery.
- The court held the trial court properly refused a duress instruction because the evidence did not support submitting duress to the jury.
- The court rejected the asserted evidentiary errors as nonprejudicial or within the trial court’s discretion.
- The court held the challenged prosecutorial argument did not warrant a mistrial and that denial of the mistrial motion was not an abuse of discretion.

## Legal Principles

- A defendant is entitled to a defensive instruction only when there is substantial evidence supporting the elements of that defense.
- Duress requires evidence of immediate, present, and impending threats of death or serious bodily harm that compel the criminal act.
- Generalized fear, past violence by others, or threats of future harm—without evidence of immediate compulsion at the time of the offense—does not require submission of duress.
- Appellate reversal for closing-argument misconduct generally requires a showing of prejudice, and mistrial rulings are reviewed for abuse of discretion.

## Conclusion

The court affirmed the robbery conviction, holding that duress was not for the jury because the record did not show the immediate, impending compulsion required under Missouri law, and finding no reversible error in the evidentiary rulings or in denying a mistrial based on the prosecutor’s argument.


State v. St. Clair, 262 S.W.2d 25 (Mo. 1953)