State v. Camplin

Missouri Court of Appeals · Criminal Law
Criminal Lawsecond-degree domestic assaultthird-degree domestic assaultstatutory ambiguityclass C felonyclass A misdemeanoraffirmedRule 30.25(b)

Facts

Tommie Camplin was convicted of second-degree domestic assault. On appeal, he argued that the governing law was ambiguous. He contended that it was unclear whether his conduct constituted second-degree domestic assault, a class C felony, or third-degree domestic assault, a class A misdemeanor. The opinion does not describe the underlying conduct in further detail.

Issue

Whether an alleged statutory ambiguity made it unclear whether Camplin's conduct constituted second-degree domestic assault rather than third-degree domestic assault, such that his conviction for second-degree domestic assault should be reversed.

Rule

A conviction will not be reversed on the basis of alleged statutory ambiguity where the court finds no error in classifying the defendant's conduct under the offense of conviction.

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Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.
In St. Louis, Jordan Pike was convicted of felony domestic assault after an altercation with his spouse. On appeal, Jordan argues only that the domestic-assault statutes are ambiguous because the same conduct could have been charged as a misdemeanor instead.

If the appellate court concludes there was no error in treating Jordan's conduct as the felony offense, what is the most likely result?

Explanation. The majority opinion establishes only a narrow rule: a conviction is not reversed based on alleged statutory ambiguity when the appellate court finds no error in classifying the conduct under the offense of conviction. Thus, if no error is found, affirmance follows. (Derived from State v. Camplin (n.d.).)