State v. Smith

DANIEL E. SCOTT, Chief Judge.

A jury found Codey Smith guilty of robbery and armed criminal action. His appeal is limited to Rule 30.20 plain error claims. 1

Principles of Plain Error Review

“Rule 80.20 is no panacea” for unpreserved error, and does not justify review of all such complaints, but is used sparingly and limited to error that is evident, obvious, and clear. State v. Campbell, 122 S.W.3d 736, 739-40 (Mo.App. 2004). “[N]ot all prejudicial error — that is, reversible error — can be deemed plain error.” State v. Dowell, 25 S.W.3d 594, 606 (Mo.App.2000). A defendant’s Rule 30.20 burden…