Coroner's Inquests in Missouri: Modern Usage of the Hue and Cry
H. Morley Swingle1
Coroner’s inquests have existed for many centuries, and can be a useful tool for both prosecutors and defense attorneys in homicide cases where suicide, accident, self-defense or another justification is a potentially valid defense.
Introduction
One man shoots another dead. The shooter himself calls 911. When the police arrive, he claims self-defense. He adamantly sticks to his story, even through vigorous interrogation. The crime scene itself neither proves nor disproves his account. Whether the killing was legally justified rests largely upon the credibility of the shooter. The prosecutor takes the charging decision under advisement. As the days go by, the situation festers. Family members of the deceased demand a murder charge, calling for the death penalty while appearing on tabloid talk shows. A spokesman for a national gun organization proclaims the shooting justified and takes up the cause of the shooter. A minister whose main congregation is the court of public opinion, and who sees every issue only through the prism of race relations, bombastically advocates the version of events from the viewpoint of whichever person (shooter or deceased) happened to be a minority. The courthouse is picketed by supporters of both sides. Even the prosecutor’s spouse weighs in with an opinion over morning coffee. The slogan of the movie Ghostbusters flashes through the prosecutor’s beleaguered mind: “Who you gonna call?”
How about the coroner?
Historical Context
The coroner’s inquest procedure dates back to at least the year 1194 in England.2 The “first finder” of a dead body was required by law to raise a “hue and cry,” thereby summoning the coroner, who would immediately empanel a coroner’s jury to conduct an inquiry into the circumstances of the suspicious death. The position of coroner, next to sheriff, was regarded as the most important position in local government.3 For many years, the coroner was required to be a knight.4 In modern Missouri, knighthood is not a prerequisite; our coroners are merely required to be county residents over the age of 21.5 Coroner’s inquests have been an important feature of Missouri death investigation in many cases over the past two centuries. In Cape Girardeau County, for instance, 919 coroner’s inquests were held between 1842 and 1932, an average of 10 per year.6 Although modern coroner’s inquests occur less frequently, they still serve important functions in the right sort of case. Many coroner’s inquest procedures established hundreds of years ago can still be of great public benefit to the modern criminal justice system in Missouri.
Modern Law
Most Missouri counties still have elected coroners. Of the 114 counties in Missouri, 100 have coroners, while the other jurisdictions now have medical examiners.7 Under state law, when a county becomes a first class county it can elect whether to retain a coroner position or switch to a medical examiner system.8 By and large, only the large metropolitan areas have opted for the expense of hiring full-time medical examiners.
Under current law, a Missouri coroner has the duty to investigate any death where the person is believed to have died: (1) by violence due to “homicide, suicide or accident;” (2) by criminal abortion; (3) by “[s]ome unforeseen sudden occurrence [where] the deceased had not been attended by a physician during the thirty-six hour[s]” preceding death; “(4) [i]n any unusual or suspicious manner; or (5) [b]y [a]ny injury or illness while in the custody of the law or while an inmate in a public institution.”9 The police have the duty to notify the coroner of such a death, and the coroner likewise has a duty to notify the police of such a death before moving the body.10 If the coroner determines that “a further inquiry and examination” is necessary in the public interest, he or she may call a coroner’s jury “to inquire how and by whom the deceased came to his death.”11 The coroner is not required to call a coroner’s inquest in every homicide; it is a discretionary matter.12 When an inquest is called, the county prosecutor should assist the coroner in preparing for the inquest, especially the preparation of the “charge” to the jury and other instructions for them, and in questioning the witnesses at the inquest.
Modern Usage
A coroner’s jury is especially helpful in a situation where a claim of self-defense or some other legal justification seems plausible. Cape Girardeau County has called coroner’s juries in recent years when a reserve police officer responding to a hospital emergency room shot a man who charged him with a knife; when two police officers killed a man in a motel room during a gunfight following a “knock and talk” search of his room; when one bar patron shot another in a gunfight at a tavern; and when nurse’s aides trying to restrain a violent teenage mental patient accidentally suffocated the youngster. In each case, the time, effort and trauma of a full-blown jury trial was avoided by the coroner’s inquest procedure.
Public Process
One public policy served by the coroner’s inquest is letting the community know the details surrounding a controversial killing by forcing the eyewitnesses to testify live and under oath in a public forum. A coroner’s jury is a “public governmental body” and its inquest is a “public meeting.”13 This can be particularly important when the prosecutor may be seriously considering not filing a criminal charge. When a prosecutor believes a killing constituted lawful self-defense, he is ethically-bound not to charge the defendant. This can produce a great deal of hoopla and suspicion if family members of the bullet-riddled corpse are loudly questioning the prosecutor’s motives, judgment and integrity. The prosecutor can always announce a decision not to file a charge without bothering with an inquest, and thereby bear all of the responsibility for the decision on the prosecutorial shoulders. On the other hand, the prosecutor might ask the coroner to call a grand jury, thereby giving the public the opportunity to hear the live testimony of the witnesses in order to judge for themselves whether a murder is being “covered up.” The public and media can attend a coroner’s inquest. All details of the homicide are made public. Citizens can see for themselves whether or not they agree with the decision made by the prosecutor, their elected public official. Thus, because of its public nature, the coroner’s inquest serves a very important function when a prosecutor is leaning toward not filing a criminal charge. In these circumstances, it amounts to a public grand jury process. One commentator noted that the inquest process “protects innocent persons who are falsely accused of crime by making known the true facts.”14
Investigative Power
The coroner’s inquest can also provide a tool by which the prosecution can enlist the aid of the coroner to subpoena recalcitrant witnesses to come forward to testify. Not only does the coroner have subpoena power,15 but a verbal order by the coroner to appear bears the same force and effect as a subpoena.16 While a subpoenaed witness can invoke a valid testimonial privilege, a witness who simply refuses to talk to the police because he or she does not want to get involved can be forced to testify. Those who fail to appear may be subjected to body attachment.17 Those who refuse to testify may be jailed until they “give such evidence or be discharged by due course of law.”18 Obviously, the Fifth Amendment would protect a suspect from being compelled to give incriminating testimony.19 A suspect who voluntarily testifies at a coroner’s inquest, however, waives the constitutional right against self-incrimination and his or her testimony may be used at trial should a charge ever be filed.20 Nevertheless, in many instances it will be in the best interests of the person who did the killing to testify at a coroner’s inquest. Cooperation at this stage could very well cause the criminal investigation to end favorably and quickly for the killer.
Avoiding a Charge
If the prosecutor has not considered the inquest procedure, the attorney for the person who committed an allegedly justified killing may want to suggest it. An inquest can bring quick closure to a homicide investigation. This might occur when a shooting was justified by self-defense, by defense of premises, in a battered spouse situation, or when the death was truly an accident or suicide.
In 1984, a reserve police officer named Winford Griffith was called to Southeast Hospital in Cape Girardeau to deal with a violent person in the emergency room. Once he confronted the man, the suspect pulled a knife and charged him. Griffith shot him twice in the chest, killing him. Eleven days later, after hearing six hours of testimony from 13 witnesses, the coroner’s jury ruled the shooting justified by self-defense.21
On February 11, 2001, two Cape Girardeau police officers, Keith May and Brad Moore, conducted a “knock and talk” consent search22 at a motel room at the Super 8 Motel in Cape Girardeau. They were responding to a tip from hotel staff who suspected the room might contain methamphetamine activity, although the information did not yet amount to probable cause. They knocked on the door and requested permission for a consent search. The two occupants, a man and woman, let them inside the room. While the officers were looking around the cramped quarters, the man pulled a gun from under a pillow on the bed and shot both policemen. Their guns had been holstered because it is hard to claim that consent given to a “knock and talk” search was truly voluntary when given at gunpoint. The officers, although wounded, were both able to draw their handguns and return fire, killing the man. A coroner’s jury ruled the homicide justified.23 In the words of the women singing the hit song Cell Block Tango in the musical Chicago, the jury ruled “he had it coming.’”24
In 2002, a man named Cleo Johns was at Ed’s Bar in Cape Girardeau when he got a call that Winford Griffith, a former friend, had just assaulted a woman, and had vowed to find Cleo Johns and kill him. Johns armed himself with a handgun. Sure enough, Griffith arrived at the bar within minutes. In an encounter reminiscent of the Wild West days, Griffith charged into the bar, gun in hand. Johns shot him dead in front of the other bar patrons. In a twist of irony proving that real life can be stranger than fiction, Griffith, the same man who had starred in the role of shooter at a coroner’s inquest in 1984, now found himself in the less-desired supporting role of corpse at a coroner’s inquest in 2002. The coroner’s jury ruled his violent death justified by self-defense.25
In 2006 in Texas County, a woman named Doris Cooper shot her husband in the back. She claimed he had been beating her, and had threatened that he was going to get a gun to kill her. As he was reaching into the end table where he kept his firearm, she drilled him in the back with a single shot from a shotgun she had hidden for just such an emergency. The physical evidence corroborated her account. The coroner’s jury ruled this battered spouse shooting justifiable, in spite of the highly suspicious location of the entry wound.26
In 1995, a violent teenage girl with mental problems was being confined at the Cottonwood Treatment Center in Cape Girardeau. When she started fighting with staff, three nurse’s aides tried to restrain her. Ultimately, the pile of struggling women went to the floor. Eventually, the girl quit struggling. Upon releasing her, the medical staff realized to their horror that they had accidentally suffocated her. A coroner’s jury was summoned and the evidence was presented to both the jury and the court of public opinion. The coroner’s jury declared that the death had been by felony.27 The prosecutor, who had been hoping to be taken off the hook by the coroner’s jury, nevertheless declined to file the charge, announcing that, in spite of the jury’s finding, he did not feel a criminal case could be proven beyond a reasonable doubt.28 This incident highlights that the prosecutor is not bound by the coroner’s jury’s finding. It is ultimately up to the prosecutor to decide whether to file the charge. Even though the verdict at the inquest was not what the prosecutor expected, it was still useful to the prosecution because it allowed the public to see the evidence on which the prosecutor ultimately based his decision not to file a homicide charge. His judgment call was never seriously questioned, as it might have been had the facts not been aired in a public forum.
Making a Filed Case Go Away
Defense attorneys should be alert to the possibility that a coroner’s inquest can also make a charge that has already been filed go away.
In New Madrid County in 1991, a man named Mike Seagraves found himself being prosecuted for murdering his live-in girlfriend. The prosecutor had charged him with first degree murder. His trial date was looming. On its face, the case appeared strong for the prosecution. Seagraves had been found in his house with the dead woman’s body. She had been shot one time in the head. The gun had been fired several times into the wall. His fingerprints were on the weapon. Things looked grim for him.
The defense intended to claim at trial that the girlfriend had committed suicide. They located witnesses who had heard her saying shortly before her death that she was going to go home and kill herself. The defendant’s story was that he had known his girlfriend was talking about suicide, but he had never gotten around to taking all of his firearms out of their house. When he came home and found her body, he was so distraught and upset that he grabbed the gun and fired several shots into the wall in frustration. The defense could also show that the right-handed dead woman had gunshot residue on her right hand, consistent with her being the one who fired the gun. Best of all, they had Dr. Mary Case, the renowned medical examiner from St. Louis. Dr. Case was willing to testify that, based upon the positioning and nature of the wounds, the gunshot residue and the evidence at the crime scene, the case appeared to be a suicide.
The defense attorney approached the prosecutor and disclosed the evidence he intended to present. He convinced the prosecutor to ask the coroner to call an inquest. The prosecutor presented the evidence, both pro and con, at the coroner’s inquest. The jury ruled the case a suicide, the murder charge was dismissed, and the defendant no longer faced the jeopardy of a criminal prosecution.29
Mechanics
How Empaneled
To empanel a coroner’s jury, the coroner issues a warrant directing the sheriff “to summon a jury of six good and lawful citizens of the county” to serve as the coroner’s jury.30 No specific statutes address whether the sheriff or coroner may simply hand-pick the six jurors, or whether the jury should be summoned in the manner used for a regular jury panel. In the past, Cape Girardeau County followed a practice whereby the coroner picked the jurors. For more recent coroner’s juries, the circuit clerk’s office has used its computer to generate names at random from the pool of potential jurors in the same way citizens are selected for regular jury duty.
Viewing Body
In past centuries, the coroner’s jurors would hearken to the “hue and cry” and hurry to the place designated by the coroner, where they would physically view the body. Missouri statutes originally talked in terms of actually having the coroner’s jury “view” the body, but in 2002 the applicable statute was amended to delete the “viewing” language and replace it with wording calling for the jurors to “appear before such coroner, at the time and place in his or her warrant expressed” to inquire how the deceased came to his or her death.31 Under the new statutory language, the jury may view the body “by photographic, electronic, or other means.”32 This is a better practice in modern times, when the coroner’s inquest may not occur for several weeks, after awaiting crime lab reports showing such things as toxicology results, fingerprint analysis, ballistics tests, DNA results or other scientific analysis. Allowing the jury to be summoned later and to view the body by photographs is clearly preferable to calling them out before the body is even buried.
Location of Inquest
The location of the coroner’s inquest rests solely within the discretion of the coroner.33 Inquests are judicial in character,34 and are usually held in a courtroom, with the coroner sitting on the bench, the coroner’s jury occupying the jury box, the prosecutor manning the counsel table, the witnesses testifying from the witness box, and the public and media sitting in the spectator seats. A courtroom is unquestionably the best location for the inquest because it sets the proper tone for the importance and dignity of the occasion.
Court Reporter
By statute, the evidence from each witness is to “be taken down in writing.”35 As a practical matter, this means that a court reporter will be present to make a transcript of the proceeding. The responsibility for having the coroner’s inquest transcribed is the duty of the coroner, rather than the prosecuting attorney.36 Older cases would allow a more cumbersome practice of having the testimony taken down in writing and subscribed by the witnesses.37 It is hard to imagine why any coroner and prosecutor today would choose this option rather than simply using a court reporter.
Inquest Procedures
The coroner swears in the jury using wording specifically prescribed by statute calling upon them to “diligently inquire” into “how and by whom the person . . . came to his death.”38 The coroner then reads a “charge” to the jury.39 It is a good idea for the prosecutor to draft the charge for the coroner, following the general format of jury instructions in criminal cases. For example, in the Cape Girardeau County case where the “victim” announced that he was going to kill Cleo Johns and tracked him to a bar, the charge told the jury of its duty to hear the evidence and determine whether the victim died by felony or justifiable homicide, instructed them upon the law of self-defense, and gave them guidelines as to the procedures to follow at the inquest.40 Prior to giving testimony, each witness is sworn by the coroner, following prescribed statutory language.41 The prosecutor should handle the questioning of the witnesses.42 The attorney for the killer may certainly supply the prosecutor with questions to ask his or her client, but the defense has “no inherent right” to cross-examine witnesses or to present evidence of its own.43 It has been suggested that, although defense counsel may not actively participate in the proceedings, he or she can be allowed to sit by the side of a witness to “aid and counsel him in giving answers to questions propounded to him so as to guard against self-incriminating testimony.”44 If a recess is taken, it is a good idea for the coroner to give an instruction warning the jurors not to talk with others about the case during the recess, patterned after MAI-CR 3d 300.04. At the close of the evidence, the coroner should send the jury to the jury room for its deliberations. It is a good idea to draft in advance the instruction given to them at that time. It should tell them how to conduct their deliberations, much like criminal instruction MAI-CR 3d 302.05.45 At the conclusion of the hearing, the coroner’s jury should deliberate in private and should then return a written verdict.46 It is good practice for the prosecutor to prepare a verdict form in advance for the jury to take into the deliberation room.47
Death By Felony
If a coroner’s jury rules that a death was the result of a felony, the coroner is to “speedily inform one or more associate circuit judges” of the county.48 The old statutory language provides that it shall be the duty of that judge to issue his process for the apprehension of such person for trial.49 As a practical matter, the prosecutor will undoubtedly have attended the hearing and will be taking whatever steps deemed necessary to see that justice is done. If the judge issues a warrant for the arrest of the killer, the prosecutor may dismiss the case if he or she believes insufficient evidence exists to convict.50 The coroner has no duty or power to order the suspect arrested.51 “Nor is the verdict of [the] coroner’s jury” subject to judicial review.52
Costs
In 1779, Maryland coroners were allowed a fixed fee of 250 pounds of tobacco for each inquest held.53 Modern coroners are paid out of the county treasury. After the inquest, the coroner is to provide the county commission “a certified statement of . . . the costs and expenses of the inquest.”54 It is the responsibility of the county commission to audit the statement and pay the lawful costs.55
Conclusion
The coroner’s inquest power can be an extremely useful tool for the criminal justice system by providing a quick and public resolution to homicides that are truly justifiable. Prosecutors and defense lawyers should keep the possibility of an inquest in mind when the right sort of case presents itself.
FORM 1
CHARGE TO CORONER’S JURY – WINFORD STERLING GRIFFITH
INTRODUCTION
The matter for which you have been called today is a coroner’s inquest into the death of Winford Sterling Griffith, supposed to have come to his death by violence, whose body was found at Southeast Hospital, 1701 Lacey Street, Cape Girardeau, Missouri, having been transported to that location from Ed’s Bar at 519 Good Hope Street in Cape Girardeau, Missouri on Friday, March 15, 2002, after an exchange of gunfire at Ed’s Bar with one Cleo Edward Johns.
Your duty is to hear evidence and determine whether Winford Sterling Griffith died by felony or by justifiable homicide.
In making that determination, you are instructed as to the law of the State of Missouri as follows:
FELONY
If you find and believe from the evidence more likely than not:
First, that on or about March 15, 2002, in the County of Cape Girardeau, State of Missouri, Cleo Edward Johns caused the death of Winford Sterling Griffith by shooting him, and
Second, that Cleo Edward Johns did not act in lawful self-defense in shooting Winford Sterling Griffith, then you should declare that Winford Sterling Griffith died as a result of a felony, and you should name in your Coroner’s verdict those whom you found to be acting unlawfully.
In determining whether Cleo Edward Johns was acting in lawful self-defense in shooting Winford Sterling Griffith, you are instructed upon the law of self-defense as follows:
JUSTIFIABLE HOMICIDE BY SELF-DEFENSE
In this State, the use of force (including the use of deadly force) to protect oneself from harm is lawful in certain situations.
A person can lawfully use force to protect himself against an unlawful attack. However, an initial aggressor, that is, one who first attacks another, is not justified in using force to protect himself from the counter-attack that he provoked.
In order for a person lawfully to use force in self-defense, he must reasonably believe he is in imminent danger of harm from the other person. He need not be in actual danger but he must have a reasonable belief that he is in such danger.
But a person is not permitted to use deadly force, that is, force that he knows will create a substantial risk of causing death or serious physical injury, unless he reasonably believes he is in imminent danger of death or serious physical injury.
And even then, a person may use deadly force only if he reasonably believes the use of such force is necessary to protect himself.
As used in this instruction, the term “reasonable belief” means a belief based on reasonable grounds, that is, grounds that could lead a reasonable person in the same situation to the same belief. This depends upon how the facts reasonably appeared. It does not depend upon whether the belief turned out to be true or false.
As to Cleo Edward Johns, if he reasonably believed he was in imminent danger of death or serious physical injury from the acts of Winford Sterling Griffith and he reasonably believed that the use of deadly force was necessary to defend himself, then he acted in lawful self-defense.
PROCEDURES
After you hear the evidence in this matter, you will retire to your jury room. You should first select one of your number to act as your foreperson and to preside over your deliberations.
You will then discuss the case with your fellow jurors. Each of you must decide the case for yourself, but you should do so only after you have considered all the evidence, discussed it fully with the other jurors, and listened to the views of your fellow jurors.
Your verdict, whether “Felony” or “Justifiable Homicide” must be agreed to by each juror.
When you have concluded your deliberations, you will complete the Verdict Form and return it to the Coroner.
FORM 2
CORONER’S JURY VERDICT
We, the undersigned Coroner’s Jurors, upon our oaths, having viewed photographs of the body, having heard the evidence, and having made all the inquiry in our power into the death of Winford Sterling Griffith, do deliver to the Coroner our verdict upon the death under consideration as follows:_______________________________________________________________________
Juror
____________________________________
Juror
____________________________________
Juror
____________________________________
Juror
____________________________________
Juror
____________________________________
Juror
The above verdict was presented to me on the _______ day of ____________, 2002.
____________________________________
Michael H. Hurst
Coroner
Footnotes
1 Mr. Swingle is the prosecuting attorney for Cape Girardeau County and a member of the Supreme Court of Missouri Committee on Criminal Procedure. He is a 1980 graduate of the University of Missouri-Columbia School of Law and the author of Scoundrels To The Hoosegow: Perry Mason Moments And Entertaining Cases From The Files Of A Prosecuting Attorney (2007). He would like to thank intern Adam E. Hanna of Southeast Missouri State University for his help with the research for this article.
2 R. F. Hunnisett, The Medieval Coroner 1 (1961).
3 18 Am. Jur. 2D. Coroners or Medical Examiners § 1 (1985).
4 Charles Gross, The Early History and Influence of the Office of Coroner, 7 Pol. Sci. Q. 656, 660 (1892).
5 Section 58.030, RSMo 2002.
6 Missouri Secretary of State, Coroner’s Inquest Database, available at http://www.sos.mo.gov/archives/resources/coroners/.
7 Missouri Coroners’ and Medical Examiners’ Association, Membership Roster, available at http://www.fidnet.com/~ewilson/roster.htm.
8 Section 58.700, RSMo 2002.
9 Section 58.451, RSMo 2002.
10 Id.
11 Sections 58.451.8 and 58.260, RSMo 2002.
12 95 Op. Att’y Gen. (1957).
13 49 Op. Att’y Gen. (1979).
14 John M. McIlroy, Jr., The Coroner v. The Medical Examiner in Missouri, 34 Mo. L. Rev. 219, 223 (1969).
15 Section 58.330, RSMo 2002.
16 Section 58.420, RSMo 2002.
17 Section 58.380, RSMo 2002.
18 Section 58.440, RSMo 2002.
19 State v. Burnett, 206 S.W.2d 345 (Mo. 1947); State v. Pearson, 270 S.W. 347 (Mo. 1925); 18 Am. Jur. 2d. Coroners or Medical Examiners Sec. 12 (1985).
20 State v. Mayabb, 316 S.W.2d 609 (Mo. 1958); State v. Black, 227 S.W.2d 1006 (Mo. 1950).
21 Mark Bliss, Jury Rules Shooting Self-Defense, Justifiable, Southeast Missourian, Dec. 28, 1984, at 1.
22 In a “knock and talk” search, officers who do not have sufficient probable cause to get a search warrant knock on the door and request consent for a search. See H. Morley Swingle & Kevin M. Zoellner, “Knock and Talk” Consent Searches: If Called by a Panther, Don’t Anther, 55 J. Mo. Bar 25 (1999).
23 Tony Hall, Police Justified in Shooting, Southeast Missourian, Mar. 31, 2001.
24 Music by John Kander, Lyrics by Fred Ebb.
25 Andrea L. Buchanan, Inquest Rules Out Homicide, Southeast Missourian, Mar. 23, 2002.
26 Interview with Michael R. Anderson, Texas County Prosecuting Attorney (April 25, 2006).
27 Chuck Miller, Coroner’s Jury Rules Teen’s Death Manslaughter, Southeast Missourian, Mar. 27, 1996.
28 Chuck Miller, No Charges in Cottonwood Death: Prosecutor Says He Can’t Prove Criminal Negligence, Southeast Missourian, Mar. 30, 1996.
29 Interview with H. Riley Bock, former prosecuting attorney of New Madrid County (April 26, 2006).
30 Section 58.260, RSMo 2002.
31 Id.
32 Section 58.360, RSMo 2002.
33 95 Op. Att’y Gen. (1957).
34 Boisliniere v. Bd. of County Comm’rs, 32 Mo. 375 (Mo. 1862).
35 Section 58.350, RSMo 2002.
36 State v. Onken, 701 S.W.2d 518 (Mo. App. W.D. 1985).
37 State v. Allen, 234 S.W. 837 (Mo. 1921).
38 Section 58.300, RSMo 2002.
39 Section 58.310, RSMo 2002.
40 See Form 1 at the conclusion of this article.
41 Section 58.340, RSMo 2002.
42 35 Op. Att’y Gen. (1951).
43 United States ex rel. Musil v. Pate, 427 F.2d 930 (7th Cir. 1970).
44 35 Op. Att’y Gen. (1951).
45 For example, in the Johns case, the coroner’s final instruction read: “Members of the jury, it is now time to retire to your jury room. You will take your written Charge and Verdict Form with you. You should first select one of your number to act as your foreperson and to preside over your deliberations. You will then discuss the case with your fellow jurors. Your verdict, whether ‘Felony’ or ‘Justifiable Homicide’ must be agreed to by each juror. When you have concluded your deliberations, you will complete and sign the Verdict Form and let us know that you have reached a verdict. We will then call the inquest back into session for the delivery of your verdict. This inquest will stand in recess until the jury has reached its verdict.”
46 Section 58.360, RSMo 2002.
47 See Form 2 at the end of this article.
48 Section 58.370, RSMo 2002.
49 Id. See also 32 Op. Att’y Gen. (1957).
50 32 Op. Att’y Gen. (1957).
51 88 Op. Att’y Gen. (1954).
52 In re Boston, 47 P.3d 956 (Wash. Ct. App. 2002).
53 Levy Court v. Coroner, 69 U.S. 501 (1864).
54 Section 58.570, RSMo 2002.
55 Id.