Justia Missouri Supreme Court Opinion Summaries

The director of revenue for the State revoked James Hill's driving privileges for a period of ten years beginning October 2000. In June 2005, Hill was convicted of the misdemeanor of possession of drug paraphernalia. In April 2011, Hill filed a petition for reinstatement of his driving privileges. The director asserted that Hill's 2005 conviction precluded reinstatement because Me. Rev. Stat. 302.060.1(9) barred reinstatement for persons convicted within the previous ten years of an offense related to alcohol, controlled substances or drugs. The trial court reinstated Hill's driving privileges and held that section 302.060.1(9) was unconstitutionally vague. The Supreme Court versed, holding that section 302.060.1(9) was not unconstitutionally vague given the facts in this case. View "Hill v. Dir. of Revenue" on Justia Law

After a jury trial Kenneth Baumruk was found guilty of the first degree murder of his wife and sentenced to death. Baumruk timely filed a pro se motion for postconviction relief. The motion court denied some of the claims without an evidentiary hearing and held an evidentiary hearing on the remaining claims. The court then issued a judgment overruling all claims put forth by the motion. The Supreme Court affirmed the motion court's judgment, holding that the motion court did not err by overruling Baumruk's claims that his competency hearing counsel, trial counsel, and appellate counsel were ineffective for numerous reasons. View "Baumruk v. State" on Justia Law

Defendant Michael Tisius was convicted of two counts of first-degree murder for killing two law enforcement officers and was sentenced to death. The Supreme Court affirmed the judgment of the circuit court, holding that the circuit court did err in (1) admitting the certified court record of the complaint for Defendant's conviction for possession of a prohibited item in the department of corrections; (2) overruling Defendant's objections to the State's cross-examination of his expert; (3) failing to intercede sua sponte at multiple times during the State's closing argument; (4) submitting verdict mechanics instructions or mitigating circumstances instructions; and (5) sentencing Defendant to death, as the imposition of the death penalty met the statutory requirements. View "State v. Tisius" on Justia Law

Kevin Bromwell and several other inmates (Appellants) of the Jefferson County Correctional Center filed a petition for declaratory judgment and injunctive relief, alleging that the circuit court's application of the Missouri Prisoner Litigation Reform Act to petitions for writs of habeas corpus violated the state and federal Constitutions. Appellants then filed a consolidated petition for writs of habeas corpus. The circuit court quashed service of process, dismissed the counts alleged in the consolidated petition for declaratory judgment for failure to state a claim upon which relief may be granted, and dismissed the petition for writs of habeas corpus without prejudice. The Supreme Court affirmed the circuit court's judgment, holding (1) the consolidated petitions for writs of habeas corpus claims were properly dismissed and there was no right to appeal; and (2) the circuit court properly dismissed Appellant's declaratory judgment petition, as Appellants failed to state claims upon which relief could be granted. View "Bromwell v. Nixon" on Justia Law

Defendant Tyler McNeely refused to consent to an alcohol breath test or a blood test after he was arrested for driving while intoxicated. The arresting patrolman, without seeking a warrant from a judge, ordered a medical professional to draw Defendant's blood. The trial court sustained Defendant's motion to suppress the results of the blood test, concluding that the nonconsensual and warrantless blood draw was a violation of Defendant's Fourth Amendment rights. The Supreme Court affirmed, holding (1) the fact that blood-alcohol levels dissipate after drinking ceases is not a per se exigency pursuant to Schmerber v. California justifying an officer to order a blood test without obtaining a warrant from a neutral judge; and (2) the arresting patrolman, therefore, was not justified in failing to seek a warrant before drawing Defendant's blood over his refusal to consent. View "State v. McNeely" on Justia Law

Jesse Dorris, Jose Lopez-McCurdy and Louis Hill were denied the right to appeal their post-conviction relief motions on the merits because they were filed out of time. The State did not raise the issue of timeliness below. The Supreme Court (1) held that, pursuant to Mo. Sup. Ct. R. 29.15 and 24.035 (the Rules), the motion court had no authority to hear the motions, regardless of the State's failure to raise the issue, because the motions were filed out of time; (2) affirmed the dismissal of Dorris' and Lopez-McCurdy's cases because they were filed outside the mandatory time limits provided in the Rules and resulted in Dorris and Lopez-McCurdy completely waiving their post-conviction relief claims; and (3) remanded Hill's case for a hearing on the timeliness of his motion. View "Dorris v. State" on Justia Law

After a jury trial, Ines Letica was found guilty of first degree assault and armed criminal action. During voir dire, defense counsel used peremptory challenges to strike four Caucasion females from the panel, to which the State raised a reverse-Batson objection, alleging that a certain venireperson was struck with the peremptory challenge on the basis of gender, race or ethnic origin. The circuit court sustained the objection as to the venireperson. The Supreme Court affirmed the circuit court's judgment, holding (1) the circuit court erred when it ruled prematurely on the reverse-Batson challenge and did not require the State to demonstrate that racial or gender discrimination was the motivating factor for the peremptory strike, but the error was harmless under the facts in this case; (2) the evidence was sufficient to sustain the verdict; (3) Letica's sentences did not constitute plain error; (4) there was no prosecutorial misconduct in this case; and (5) the admission into evidence of certain photographs did not constitute manifest injustice or miscarriage of justice. View "State v. Letica" on Justia Law

This case involved four appeals that were consolidated because each involved the issue of whether evidence obtained in a search of a motor vehicle incident to a traffic arrest was admissible. In each case, there was no reason to believe that evidence of the crime for which each Defendant was arrested was in any of their vehicles. The searches were performed in compliance with binding appellate precedent, but while these cases were pending, Arizona v. Gant was decided, holding that such searches were unlawful. Each defendant, relying on Gant, filed a motion to suppress the evidence obtained from the searches. At issue before the Supreme Court was whether the exclusionary rule suppresses evidence obtained in a search conducted in compliance with binding precedent when such precedent was later overturned. The Supreme Court held (1) in accord with Davis v. U.S., the exclusionary rule did not apply because the searching officers acted in objectively reasonable reliance on settled, binding appellate precedent; and (2) the trial court's judgments sustaining the motions to suppress in three cases were reversed and remanded, and the trial court's judgment in the remaining case overruling the defendant's motion to suppress was affirmed. View "State v. Johnson" on Justia Law

Defendant was convicted by a jury of felonious restraint, deviate sexual assault, and first-degree sexual misconduct. Prior to sentencing, Defendant entered into an agreement with the State in which Defendant would plead guilty to two additional criminal counts and waive his rights to a jury trial, to direct appeal, and to seek post-conviction relief. In exchange, the State recommended that Defendant be sentenced to a combined total of fifteen years incarceration on all counts. The circuit court rendered and judgment and sentence in accord with the agreement. Defendant subsequently filed an amended motion for post-conviction relief, alleging ineffective assistance of counsel for, inter alia, incorrectly advising Defendant to waive his rights to a direct appeal. The motion court denied the motion. The Supreme Court vacated the motion court's judgment, holding that Defendant knowingly, voluntarily, and intelligently agreed to waive his post-conviction rights after his trial. Remanded with instructions to dismiss Defendant's post-conviction motion. View "Krupp v. State" on Justia Law

Defendant pleaded guilty to two counts of stealing property of a value of more than $500. As part of the plea agreement, Cooper waived his right to file any future motion for post-conviction relief under Mo. R. Crim. P. 24.035 in exchange for the State recommending a fifteen-year sentence on each count to run concurrently with a suspended execution of the sentences and a five-year probationary term. The circuit court rendered judgment and sentences in accord with the plea agreement. After Defendant violated the terms of his probation, his fifteen-year sentences were ordered executed. Defendant subsequently filed a Rule 24.035 motion for post-conviction relief, alleging that defense counsel was ineffective. The motion court overruled the motion on the merits. The Supreme Court vacated the motion court's judgment, holding that Defendant knowingly, voluntarily, and intelligently waived his post-conviction rights. Remanded with instructions to dismiss Defendant's post-conviction motion. View "Cooper v. State" on Justia Law