Justia Missouri Supreme Court Opinion Summaries

After a jury trial, Plaintiff was found guilty of first-degree murder and armed criminal action. The circuit court sentenced Defendant to death. The Supreme Court affirmed the judgment, holding (1) the trial court did not plainly err in its rulings regarding the jury and jury instructions; (2) the prosecutor did not engage in improper arguments or make improper comments; (3) the trial court did not err in its evidentiary rulings; (4) the trial court did not err in its rulings during the penalty phase; and (5) in this case, the death penalty complied with all statutorily proportionality requirements. View "State v. McFadden" on Justia Law

In 2010, the General Assembly enacted the Missouri Secure and Fair Enforcement Mortgage Licensing Act (Missouri SAFE Act), which provides that the director of the Missouri Division of Finance shall not issue a mortgage loan originator license to an applicant who has been convicted of or pleaded guilty to a felony within seven years prior to the date of the application. When Plaintiff subsequently submitted an application for a mortgage loan originator license, the director denied the license pursuant to the Act because Plaintiff had pleaded guilty to a felony in 2006. The circuit court entered a declaratory judgment finding that the Act was unconstitutional as applied to Plaintiff. The Supreme Court reversed, holding that, as applied to Plaintiff, the statute (1) was not an unconstitutional bill of attainder; (2) did not violate the Missouri Constitution's ban on retrospective laws; and (3) did not violate Plaintiff's right to procedural and substantive due process. View "Garozzo v. Mo. Dep't of Ins., Div. of Fin." on Justia Law

After a jury trial, Defendant was convicted of two counts of harassment, one under Mo. Rev. Stat. 565.090.1(2) and one under section 565.090.1(5), and one count of possession of marijuana. The harassment charges stemmed from emails Defendant sent to public officials that contained personally offensive language and references to sawed-off shotguns, assassinations, and domestic terrorism. The Supreme Court affirmed in part and reversed in part, holding (1) the content of Defendant's emails did not constitute protected speech, and therefore, section 565.090.1(2) was constitutional as applied to Defendant, and there was sufficient evidence to support his conviction on that count; and (2) the judgment as to the second count of harassment was set aside, as State v. Vaughn invalidated section 565.090.1(5), and manifest injustice would result if the conviction under that statute was not reversed. View "State v. Wooden" on Justia Law

After a jury trial, Defendant was convicted of murder, assault, burglary, and armed criminal action. Defendant subsequently filed a petition for writ of habeas corpus, petitioning the Supreme Court to vacate his convictions and to grant him a new trial because newly discovered evidence showed (1) the State violated Brady v. Maryland by withholding material, favorable evidence, and (2) the lack of disclosure of this Brady material was prejudicial. After a hearing, a special master found that the State had violated Brady in at least two important and material respects and that the State's failure to produce this Brady material was prejudicial. The Supreme Court concluded that substantial evidence supported the master's findings and, accordingly, ordered that Defendant's convictions be vacated and ordered him discharged from the custody of the department of corrections unless the State filed in the circuit court an election to retry him. View "State ex rel. Woodworth v. Denney" on Justia Law

Appellants, Father and Son, were arrested for driving while intoxicated during separate traffic stops. Preliminary breath tests showed Appellants' blood-alcohol contest to be over the legal limit. Father agreed to take a breathalyzer test but refused to provide sufficient breath to perform the test, and Son refused to take the breathalyzer test. The director of revenue revoked Appellants' driving privileges for one year. Appellants filed petitions for review, which the circuit court denied. Appellants appealed, asserting (1) the trial court violated their due process rights by admitting the director's records into evidence without providing them the opportunity to confront and cross-examine the director's witnesses who created the records; and (2) Mo. Rev. Stat. 302.312, which authorizes the admission of the director's records in evidence in court and administrative proceedings, is unconstitutional. The Supreme Court affirmed, holding that the provision of section 302.312 authorizing the admission of the director's records by the trial court did not deny Appellants their constitutional rights to confrontation and cross-examination, as Appellants had the right to subpoena witnesses to appear at the trials on their petitions for review. View "Doughty v. Dir. of Revenue" on Justia Law

Defendant pleaded guilty to three counts of statutory sodomy in the first degree. Before trial, a third amended information was filed that charged Defendant as a predatory sex offender on Counts I and III. A factual basis of Defendant's guilt and status as a predatory sex offender was established at the plea hearing. Defendant filed a motion for post-conviction relief, alleging (1) his constitutional right to a jury trial was denied when the circuit court overruled his motion challenging the trial court's determination of his classification as a predatory sexual offender under Mo. Rev. Stat. 558.018, and (2) his due process rights were violated when the trial court overruled his motion challenging the hearing classifying him as a predatory sexual offender under Mo. Rev. Stat. 558.021.2 before the commencement of the scheduled jury trial. The motion court overruled Defendant's post-conviction motion without an evidentiary hearing. The Supreme Court affirmed, holding that the motion court did not clearly err in determining Defendant waived his constitutional challenges when he pleaded guilty. View "Garris v. State" on Justia Law

In 1983, Respondent pleaded guilty to one count of first-degree sexual assault. In 1995, Missouri's Sex Offender Registration Act (SORA) became effective, requiring Respondent to register as a sex offender. In 2010, Respondent filed a declaratory judgment action asserting that SORA violates Mo. Const. art I, 13 and that he was not required to register pursuant to the federal Sexual Offenders Registration and Notification Act (SORNA). The trial court (1) entered a declaratory judgment finding that, as applied to Respondent, SORA violated the bar against the enactment of retrospective state laws set forth in article I, section 13; and (2) declined to address the applicability of SORNA, therefore declining to order Defendants to remove Respondent's name from the registry and to destroy all registration records. The Supreme Court (1) reversed the judgment to the extent it held that the trial court was without authority to address the applicability of SORNA and that the SORA registration requirements violated article I, section 13 as applied to Respondent; and (2) affirmed the judgment to the extent that it did not order Defendants to destroy the registration records. View "Doe v. Toelke" on Justia Law

Defendant appealed the circuit court's judgment convicting him of five counts of possession of child pornography. Defendant asserted three points on appeal. The Supreme Court affirmed the judgment, holding (1) the trial court did not err in overruling Defendant's motion to suppress an affidavit offered in support of the search warrant used to seize the evidence because the affidavit established probable cause; (2) the entry of five separate convictions did not constitute double jeopardy or violate Defendant's rights to due process and trial by jury; and (3) the trial court properly admitted evidence of the content of resumes found on Defendant's computer. View "State v. Roggenbuck" on Justia Law

Appellant was convicted by a jury of first-degree murder, kidnapping, attempted forcible rape, and armed criminal action. The trial court sentenced Appellant to death and three life sentences to be served consecutively. After the Supreme Court affirmed his convictions, Appellant filed a motion for post-conviction relief, alleging several instances in which his trial counsel rendered ineffective assistance. The motion was overruled after an evidentiary hearing. The Supreme Court affirmed the judgment denying post-conviction relief, holding that the motion court did not clearly err in denying Appellant post-conviction relief, as Appellant's assertions of ineffective assistance of counsel were without merit. View "Johnson v. State" on Justia Law

The State appealed two judgments declaring Mo. Rev. Stat. 556.036 unconstitutional and dismissing, with prejudice, the criminal charges against Grant Mixon and Jeffrey Anderson. The judgments of the circuit court declared section 556.036 unconstitutional for conflicting with Mo. Const. art. I, 17, which prohibits felony prosecutions "otherwise than by indictment or information," because the circuit court determined the statute allowed for prosecution of a felony by complaint. The Supreme Court reversed, holding that Mixon and Anderson failed to demonstrate that section 556.036.5 "clearly and undoubtedly" violated Mo. Const. art. I, 17. Remanded. View "State v. Mixon" on Justia Law