Supreme Court of Missouri

State of Missouri v. Jacob Hilbert

March 21, 2023

Summary

The Court affirmed Hilbert's convictions after finding no plain error in the circuit court's decision to conduct a bench trial or admit the victim's forensic interview recording. Although Hilbert was not personally questioned before trial and did not execute a written jury waiver, the record as a whole established that his waiver was knowing, voluntary, and intelligent. The recording was properly admitted because its existence and the forensic interviewer's testimony established the statutory foundational requirements.