Justia Missouri Supreme Court Opinion Summaries

Craig M. Wood was convicted of abducting and murdering 10-year-old Hailey Owens in Springfield, Missouri. After eyewitnesses reported the abduction and provided Wood’s license plate number, police traced it to Wood's residence. Upon searching his home, officers found Hailey’s body in the basement, along with evidence of sexual assault and materials indicating Wood’s sexual interest in young girls. Wood was tried and found guilty of first-degree murder and sentenced to death.The Circuit Court of Greene County presided over Wood’s jury trial, entered judgment, and imposed the death sentence after the jury found multiple aggravating circumstances. The Supreme Court of Missouri previously affirmed Wood’s conviction and sentence on direct appeal in State v. Wood, 580 S.W.3d 566 (Mo. banc 2019). Wood then filed a Rule 29.15 motion for postconviction relief, arguing ineffective assistance of counsel on numerous grounds related to evidence, trial strategy, and mitigation. The motion court held an evidentiary hearing and denied the motion, finding no basis for relief.On appeal to the Supreme Court of Missouri, Wood raised 22 points concerning counsel’s performance and other alleged errors. The court reviewed whether the motion court’s findings and conclusions were clearly erroneous, applying the standard set forth in Rule 29.15(k). The Supreme Court of Missouri held that none of Wood’s claims demonstrated deficient performance or prejudice under the Strickland v. Washington standard. The court found the motion court’s factual determinations and legal conclusions were not clearly erroneous and affirmed the denial of postconviction relief. The judgment overruling Wood’s Rule 29.15 motion was affirmed. View "Wood vs. State of Missouri" on Justia Law

The Missouri General Assembly enacted two statutes effective August 28, 2023: the SAFE Act, which generally prohibits health care providers from performing gender transition surgeries or prescribing cross-sex hormones and puberty-blocking drugs for minors, and the Medicaid ban, which precludes MO HealthNet payments for such treatments when used for gender transition. The statutes include specific exemptions, such as for treatment of certain medical conditions and for minors already receiving such care prior to enactment. E.N., on behalf of her minor child and joined by medical professionals and organizations, challenged both laws, alleging violations of equal protection, due process, and the gains of industry clause under the Missouri Constitution.The Circuit Court of Cole County conducted a two-week bench trial and entered judgment in favor of the State, upholding the constitutionality of both statutes. The court found the challengers had raised only facial challenges and determined that neither statute violated the constitutional provisions cited. The challengers appealed, raising multiple points of error regarding the constitutional analysis and factual findings at trial.The Supreme Court of Missouri reviewed the circuit court’s determination de novo, applying a presumption of constitutionality. Relying on recent decisions from the United States Supreme Court and the United States Court of Appeals for the Eighth Circuit, the court held that both statutes classify based only on age and medical use, not on sex or transgender status. Thus, rational-basis review applied. The court found that the statutes are rationally related to legitimate state interests, such as safeguarding minors and managing public resources, and do not infringe fundamental rights. The court affirmed the circuit court’s judgment, concluding that the challengers failed to demonstrate any constitutional violation. View "E.N. v. Kehoe" on Justia Law

Richard James Johnson was charged with three moving violations in Missouri, including a class E felony charge for driving while intoxicated (DWI) as a persistent offender. The persistent offender charge was based on Johnson’s alleged prior DWI convictions on two separate occasions. Johnson argued that, under recent Supreme Court precedent, any fact that could increase the range of punishment—such as whether prior DWI convictions occurred on separate occasions—must be determined by a jury, not solely by a judge.The Circuit Court of Franklin County agreed with Johnson and dismissed the class E felony DWI charge, finding that the statute governing persistent offender status violated Johnson’s Fifth and Sixth Amendment rights by not requiring a jury determination of the “separate occasions” element. The State sought review from the Missouri Court of Appeals, which denied its writ petition. The State then sought relief from the Supreme Court of Missouri, which issued a preliminary writ of prohibition.The Supreme Court of Missouri reviewed whether section 577.023.2, which assigns the fact-finding responsibility for persistent offender status to the trial judge, is facially unconstitutional. The court held that the statute is not facially unconstitutional because it is possible for the jury to determine the relevant facts in accordance with constitutional requirements. The statute can be applied constitutionally if, after the judge’s initial finding, the jury also finds beyond a reasonable doubt that the defendant is a persistent offender. Therefore, the circuit court lacked authority to dismiss the felony charge on facial constitutional grounds. The Supreme Court of Missouri made permanent its preliminary writ of prohibition, ordering the circuit court to set aside its dismissal of the class E felony DWI charge. View "State ex rel. Catherine Hanaway vs. Hellmann" on Justia Law

Richard Neil Burkett was involved in a physical altercation with his brother-in-law at a convenience store in Texas County, Missouri. Witnesses stated that after being separated from his brother-in-law, Burkett pointed a semiautomatic handgun at him, threatened him, and pulled the trigger, although the gun did not fire. Burkett gave several inconsistent accounts to law enforcement, at first denying having a gun, then claiming self-defense, and finally admitting to pointing the gun after the fight was over. At trial, Burkett’s defense was that he never intended to harm his brother-in-law and only sought to scare him, arguing his gun was unloaded and he lacked intent to injure.The Circuit Court of Texas County conducted a jury trial, where Burkett was found guilty of first-degree assault and armed criminal action. During trial, Burkett did not request a self-defense instruction nor object to the jury instructions, and his counsel did not object to the State’s closing argument, which inaccurately stated that intent was not required for first-degree assault. Burkett’s post-trial motion did not raise these issues.The Supreme Court of Missouri reviewed Burkett’s appeal, in which he requested plain error review on two grounds: the lack of a self-defense instruction and the absence of a curative instruction after the State’s misstatement of law in closing argument. The court held that although Burkett may have injected self-defense into the case through his testimony, he failed to request the instruction or object to its absence, and his trial strategy was inconsistent with self-defense. Similarly, Burkett did not object to the State’s closing argument or request a curative instruction. The Supreme Court of Missouri exercised its discretion to decline plain error review for both claims and affirmed the judgment of the circuit court. View "State v. Burkett" on Justia Law

On February 4, 2020, Isis S. Jones engaged in a series of phone calls with D.W. while D.W. was at Victim’s apartment. After a heated argument, Victim drove D.W. to her aunt’s house, during which Jones continued calling. Near their destination, Victim heard a gunshot, stopped her car, and Jones approached the vehicle, hitting the driver’s side window with a gun. D.W. exited and fought with Jones, while Victim drove away, hearing a second gunshot. Police later observed a bullet hole in Victim’s vehicle, and Victim identified Jones as the shooter. Jones was charged with unlawful use of a weapon—specifically, the class B felony of shooting at a motor vehicle—and an accompanying charge of armed criminal action.The Circuit Court of the City of St. Louis conducted a jury trial, during which the jury was instructed to decide if Jones had shot “into” a motor vehicle, which corresponds to a class E felony, rather than “at” a motor vehicle as charged. Jones did not object to this instruction. The jury found Jones guilty of unlawful use of a weapon and armed criminal action. Jones subsequently entered into a sentencing agreement, receiving a 15-year sentence for the weapon charge (execution suspended for probation) and three years for armed criminal action. Jones appealed, arguing for the first time that the variance between the charged offense and the jury instruction led to manifest injustice due to the greater sentence imposed.The Supreme Court of Missouri reviewed Jones’ claim under Rule 30.20 for plain error, which allows discretionary review of unpreserved errors resulting in manifest injustice. The court held that Jones failed to establish substantial grounds that the circuit court committed plain error, as the distinction between shooting “at” and “into” a vehicle did not constitute a facially evident, obvious, and clear error. The court declined plain error review and affirmed the circuit court’s judgment. View "State v. Jones" on Justia Law

Law enforcement in Cass County, Missouri received a report on July 12, 2021, alleging that Israel Barrera molested a fourteen-year-old girl over several years. A subsequent medical examination confirmed that the girl had contracted trichomoniasis, a sexually transmitted disease, and she denied having any consensual sexual partners. Barrera was taken into custody on September 1, 2021, and officers initially seized a urine sample and buccal swab pursuant to a warrant. However, the urine sample was unusable, leading law enforcement to seek new warrants: one to seize another urine sample (warrant 1) and one to test that sample (warrant 2). The urine sample seized under warrant 1 tested positive for trichomoniasis.The Circuit Court of Cass County found that warrant 1 failed to establish probable cause to seize and test Barrera’s urine, and consequently suppressed the urine test results. The court also determined that the good-faith reliance exception to the exclusionary rule did not apply because the supporting affidavit was so lacking in probable cause that a reasonable officer could not rely on it. The court further found warrant 2 unnecessary, as warrant 1 authorized both the seizure and search of the urine. The state appealed this suppression order.The Supreme Court of Missouri reviewed the case and held that the issuing judge had a substantial basis to conclude that probable cause supported the application for warrant 1. The Court found that the corroborative details in the affidavit—such as medical confirmation of the STD and the victim’s denial of consensual partners—provided sufficient factual support for probable cause under a commonsense, totality-of-the-circumstances approach. Therefore, the Supreme Court of Missouri reversed the Circuit Court’s suppression of the urine test results and remanded the case for further proceedings. The Court also affirmed the finding that warrant 2 was unnecessary. View "State v. Barrera" on Justia Law

Neil Maune and Marcus Raichle formed a general partnership known as the Maune Raichle Law Firm, which later took out life insurance policies for each partner, naming the partnership as beneficiary. In 2011, Maune, Raichle, and three others established a new law firm, MRHFM, governed by an operating agreement containing an arbitration clause and a delegation provision referencing the American Arbitration Association rules. MRHFM took over premium payments for the life insurance policies, but only Raichle’s policy was amended to name MRHFM as beneficiary. After Maune’s death, the death benefit from his policy was paid to the original partnership, not MRHFM. The Estate of Neil Maune sued Raichle and the partnership, alleging wrongful retention of the insurance proceeds, tortious interference, unjust enrichment, and breach of fiduciary duty.The Circuit Court of St. Louis County denied the defendants’ motion to compel arbitration, reasoning that the partnership was not a party to the operating agreement and thus could not enforce its arbitration provision. The Estate argued that Maune and Raichle signed the agreement only as members and managers of MRHFM, not as partners of the original partnership, and that the claims did not fall within the scope of the arbitration agreement.The Supreme Court of Missouri reviewed the case de novo and held that, under Missouri’s aggregate theory of partnerships, the partnership has no legal existence separate from its partners. Because Maune and Raichle were the only partners and signed the operating agreement in their individual capacities, they bound themselves and the partnership to the arbitration agreement. The Court further held that, due to the delegation provision, questions about the scope of the arbitration agreement must be decided by the arbitrator. The Supreme Court of Missouri vacated the circuit court’s order and remanded with instructions to compel arbitration. View "Maune vs. Raichle" on Justia Law

Amanda Mire was charged with driving while intoxicated. She filed two motions in the Circuit Court of Greene County: one to suppress statements she made after emergency medical personnel involuntarily administered a tranquilizing drug, and another to suppress the results of a blood test taken when she was unable to knowingly consent. After a hearing, the circuit court orally ruled in favor of Mire on both motions, finding that her statements and the blood test results should be suppressed due to her inability to knowingly and voluntarily consent while under the influence of the drug.On February 26, 2024, the circuit court entered a docket entry reflecting its ruling, which unequivocally stated that the statements made after administration of the drug and the consent to the blood draw were suppressed. The court scheduled the next setting for the case and invited Mire’s counsel to provide a written order consistent with the oral pronouncement. On March 11, the court entered a formal “judgment and order” that repeated the substance of the February 26 docket entry. The state filed its notice of appeal on March 11, identifying the March 11 order as the one being appealed.The Supreme Court of Missouri reviewed the case and determined that, under section 547.200.4, the state was required to file its notice of appeal within five days of the entry of the order suppressing evidence. The Court held that the February 26 docket entry constituted the operative order with the substantive effect of suppressing the evidence. Because the state’s notice of appeal was filed more than five days after the February 26 order, the Supreme Court of Missouri dismissed the appeal as untimely. View "State of Missouri vs. Mire" on Justia Law

Phillip Weeks submitted a request under Missouri’s Sunshine Law to the St. Louis Metropolitan Police Department, seeking files containing traffic stop data from 2014 through 2018, specifically in spreadsheet (Excel) format and including officer identification numbers. The Department initially offered to provide traffic analysis reports with redacted officer numbers for a fee, which Weeks declined. During discovery in the resulting lawsuit, the City produced .CSV files containing the requested data. Weeks acknowledged these files matched his request in content but maintained he wanted the data in Excel spreadsheet format. Testimony at trial established that the Department did not maintain the data in Excel format, and there was conflicting evidence about whether the .CSV files could be accurately converted to Excel.The Circuit Court of the City of St. Louis found in favor of the City, concluding that the City did not possess an existing record in the specific format Weeks requested. The court determined that the City had not violated the Sunshine Law because it did not withhold any records it actually maintained in the requested format. Weeks appealed, arguing that the judgment was against the weight of the evidence, and also contended that the City’s admissions during litigation established it had responsive files at the time of his request.The Supreme Court of Missouri reviewed the case and affirmed the circuit court’s judgment. The Court held that Weeks failed to follow the required analytical framework for challenging a judgment as against the weight of the evidence. Specifically, he did not identify all favorable evidence supporting the judgment or address conflicting evidence in accordance with the trial court’s credibility determinations. The Court also found that the City’s admissions did not establish it possessed records in the requested format. The judgment in favor of the City was affirmed. View "Weeks vs. City of St. Louis" on Justia Law

The case concerns a defendant who, in July 2019, orchestrated a plan to lure a man he believed had wronged him to a house in Springfield, Missouri. The defendant rented a U-Haul van, enlisted two friends, and communicated his intent to harm the victim through text messages and conversations. On the night in question, he picked up the victim, brought him to the designated house, and later drove away with the victim, who was bound and injured. The defendant’s subsequent actions included searching online for ways to dispose of a body, coercing others to help clean the van, and attempting to destroy evidence. The victim was never seen again, and his body was not found, but his blood and personal items were recovered from the van and from a bag the defendant tried to have disposed of.After these events, the Circuit Court of Greene County tried the defendant on charges of first-degree murder and first-degree kidnapping. The jury found him guilty on both counts. At sentencing, the court orally pronounced consecutive life sentences: life without parole for murder and life with the possibility of parole for kidnapping. However, the written judgment mistakenly recorded the sentences as 999 days for each count. The defendant appealed, arguing insufficient evidence for conviction and a material discrepancy between the oral and written sentences.The Supreme Court of Missouri reviewed the case. It held that the evidence was sufficient for a reasonable jury to find the defendant guilty of both first-degree murder and first-degree kidnapping, rejecting the defendant’s arguments regarding the corpus delicti doctrine and the statutory requirements for kidnapping. The court also clarified the correct legal standard for “substantial period” in kidnapping cases. The court affirmed the convictions but remanded the case solely to correct the written judgment to match the oral pronouncement of sentences. View "State v. Winter" on Justia Law