State v. Rumble

BILLINGS, Judge.

Defendant Michelle Rene Rumble was convicted of first degree felony murder [§ 565.003, RSMo 1978]1 and sentenced to life imprisonment. On appeal to the Missouri Court of Appeals, Eastern District, defendant contended that the trial court erred in refusing to instruct the jury on the defense of duress. The court of appeals agreed with defendant that duress should be a defense to felony murder because it would be available as a defense to the underlying felony of robbery.2 The court held that failure to instruct on duress constituted error; however, the court also observed that…