Justia Missouri Supreme Court Opinion Summaries

Defendant was charged with first-degree murder and armed criminal action. Prior to trial, Defendant filed a motion to suppress statements he made to police after being read his Miranda rights. The trial court sustained the motion, concluding that Defendant’s statement, “I ain’t signing shit without my attorney” was an invocation of his right to counsel. The Supreme Court reversed, holding that Defendant failed to clearly and unequivocally assert his Fifth Amendment right to counsel, and even assuming Defendant’a partially invoked his right to counsel, there was no Fifth Amendment violation when the police questioned Defendant after he refused to sign a consent to search form. View "State v. Holman" on Justia Law

After a jury trial, Defendant was convicted of second-degree burglary and stealing. The convictions were affirmed on direct appeal. Thereafter, Defendant filed a petition for post-conviction relief, arguing that his counsel was ineffective for failing to request an instruction on the lesser-included offense of trespass as an alternative instruction to second-degree burglary. The circuit court overruled Defendant’s motion following an evidentiary hearing. The Supreme Court affirmed, holding that counsel’s performance did not fall below an objective standard of reasonableness under the performance prong of Strickland v. Washington and that there was no need to address the prejudice prong. View "McNeal v. State" on Justia Law

This case centered around Amendment No. 3, a constitutional amendment proposed by initiative petition. After the Secretary of State certified Amendment No. 3 for the November 8, 2016 general election ballot, various individuals (collectively, “Opponents”) brought three separate cases pursuant to Mo. Rev. Stat. 116.200.1 seeking to reverse this decision. The trial court entered judgment against the Opponents. The Supreme Court affirmed, holding (1) the proponents submitted a sufficient number of valid signatures in support of the amendment to qualify for the ballot; (2) the amendment does not, on its face, amend or create more than one article of the Missouri Constitution; (3) the amendment does not violate the constitutional prohibition against appropriation by initiative; and (4) the remainder of the Opponents’ substantive challenges were premature. View "Boeving v. Kander" on Justia Law

After a jury trial, Defendant was found guilty of first-degree assault and armed criminal action. Defendant appealed, arguing that the trial court erred in denying his challenge during voir dire to one of the prosecutor’s peremptory strikes under Batson v. Kentucky because the prosecutor failed to offer a race-neutral explanation for striking the venireperson. The Supreme Court vacated Defendant’s convictions, holding that the trial court clearly erred in denying Defendant’s Batson challenge where the prosecutor failed to offer a reasonably specific and clear race-neutral explanation for the strike. Remanded. View "State v. Meeks" on Justia Law

In April 2015, the Missouri General assembly passed House Bill 150 (HB 150), which made changes to Missouri’s unemployment benefits compensation statutes. The Governor subsequently vetoed HB 150. In September 2015, during a veto session, the Missouri Senate reconsidered HB 150 and voted to override the governor’s veto. Appellants filed a declaratory judgment action seeking a declaration that HB 150 is unconstitutional and requested an injunction prohibiting HB 150 from being executed or enforced. The Supreme Court reversed, holding that the Senate lacked authority to vote to override the Governor’s veto during the veto session because only bills returned by the Governor on or after the fifth day before the end of the regular legislative session can be taken up during a September veto session. View "Pestka v. State" on Justia Law

Plaintiffs the Missouri Municipal League, the City of Springfield, and Richard Sheets appealed a circuit court's judgment for the State on plaintiffs' challenge to the constitutional validity of two bills passed by the General Assembly. In 2013, the General Assembly passed House Bill 331 and House Bill 345, which repealed and enacted in lieu thereof numerous sections dealing with local government control over telecommunications infrastructure permitting and public right-of-way. Later that year, a circuit court ruled H.B. 331 and H.B. 345 were enacted in violation of procedural requirements of the Missouri Constitution. The State appealed the circuit court's judgment to the Missouri Supreme Court. With the State's appeal still pending, the General Assembly passed Senate Bill 649 and Senate Bill 650 in early 2014. S.B. 649 and S.B. 650 repealed and enacted in lieu thereof some of the same sections as had H.B. 331 and H.B. 345 and, in doing so, set forth the text of H.B. 331 and H.B. 345 as the then-existing law for the relevant sections with proposed changes noted. Two days before S.B. 649 and S.B. 650 became effective (and two days before the Supreme Court dismissed the State's appeal in the H.B. 331 and H.B. 345 case), plaintiffs brought suit challenging S.B. 649 and S.B. 650 under the Missouri Constitution. Plaintiffs sought a declaratory judgment and injunctive relief, claiming: (1) the contents of the bills violated article I, section 13's prohibition against retrospective laws; article III, section 40(28)'s prohibition on special laws, and article X, section 21's prohibition on unfunded mandates; and (2) the bills were enacted in violation of article III, section 28. The State moved to dismiss the substantive claims, and both sides moved for a judgment on the pleadings for the enactment claims. The circuit court sustained the State's motions, and plaintiffs appealed to the Supreme Court. After review, the Supreme Court concluded the State was entitled to judgment on the pleadings on this claim. View "Missouri Municipal League v. Missouri" on Justia Law

Ryan Amorine sought a writ of prohibition to prevent the trial court from holding a probation revocation hearing after Amorine’s term of probation expired. On May 4, 2011, Amorine pleaded guilty to possession of a controlled substance and second-degree domestic assault. After accepting his guilty plea, the trial court suspended the imposition of sentence and placed Amorine on supervised probation for five years. The trial court also imposed special conditions upon Amorine, which included community service and paying court costs. In 2013, a probation violation report was filed alleging that Amorine failed to pay his court costs or report any community service hours. Amorine admitted the violation in an attachment to the probation violation report. A second probation violation report was filed in 2014, again alleging Amorine failed to pay his court costs or perform his community service hours. The trial court suspended Amorine’s probation and set the matter for a hearing. At the hearing, Amorine admitted to the violation. The court extended Amorine’s probation for an additional year. In early 2015, the Board of Probation and Parole filed a “Case Summary Report” and a “Field Violation Report.” Both documents informed the court that Amorine had an earned discharge date of July 13, 2015, and with continued supervision compliance, an optimal discharge date of April 1, 2015. Both reports also indicated that the only violation of Amorine’s probation was his failure to report any community service hours he performed and the failure to pay his court costs. However, the Field Violation Report recommended that the trial court revoke Amorine’s probation, place him on a new term of suspended execution of sentence probation, direct him to pay his court costs, and perform community service work. In 2015, the court issued an order suspending Amorine’s probation. The docket sheets reflected that the court continued and rescheduled the probation revocation hearing several times in 2015; both Amorine and the state appeared at every court date. By fall 2015, Amorine, his counsel, and the state all appeared for another probation revocation hearing, but the cause was passed again. The court continued to hold case reviews on December 15, 2015, and February 17, 2016, and scheduled the next case review for April 19, 2016. The Supreme Court concluded that the facts and circumstances in this case demonstrated "unequivocally" that it needed to exercise its discretion to issue a writ of prohibition to remedy an excess of authority. The Supreme Court concluded the trial court exceeded his authority in continuing Amorine’s probation revocation hearing indefinitely after Amorine should have been discharged. Therefore, the preliminary writ of prohibition was made permanent, and the trial court was directed to discharge Amorine from probation. View "Missouri ex rel. Ryan Amorine vs. Honorable Kelly Wayne Parker" on Justia Law

Peggy Stevens McGraw and Samuel C. Jones filed suit alleging the State erroneously implemented the 2010 compensation schedule adopted by the Missouri Citizens' Commission on Compensation for Elected Officials pursuant to Mo. Const. art. XIII, sec. 3. They claimed that as a result of this error they were underpaid for their services, which also resulted in underpaid retirement benefits. The trial court dismissed with prejudice all counts raised by the appellants, and the Supreme Court affirmed that dismissal. The Supreme Court found the trial court correctly concluding that appellants' claims were based on an interpretation of art. XIII, sec. 3 that was incorrect as a matter of law and that retirement benefits were properly calculated. View "McGraw v. Missouri" on Justia Law

Rachel Johns sought the Democratic party’s nomination for Missouri State Representative in the District 76. She filed a declaration of candidacy with the Missouri Secretary of State, in which she stated under oath, that she “will qualify” to hold the office of state representative pursuant to the Missouri Constitution’s requirements for that office. Respondent Joshua Peters, another candidate for the Democratic party’s nomination for Missouri State Representative in the District 76, filed a petition pursuant to section 115.526, RSMo 2000, seeking to disqualify Johns as a candidate and have her name removed from any official election ballot. Peters argued that Johns could not meet the two-year durational voter registration requirement of article III, section 4 of the Missouri Constitution because she did not register to vote until February 4, 2015, which was less than two years before the general election date of November 8, 2016. Although Johns agreed that she did not meet the two-year voter registration requirement, she argued that such requirement is constitutionally invalid as applied to her. The circuit court determined that the voter registration requirement did not violate the First or Fourteenth Amendments. Johns appealed. The Supreme Court affirmed: "The State’s justification for the durational voter registration requirement’s burden on voting rights is the same as the justification it offers for the burden on Johns herself. The State’s interests in regulating the fairness of its elections and ensuring that candidates for state representative demonstrate sufficient seriousness about the electoral systems and social and civic engagement are legitimate. The two-year durational voter registration requirement is rationally related to those interests and a reasonable method of furthering them. Accordingly, article III, section 4 does not violate the First Amendment voting rights of the voters of District 76." View "Peters v. Johns" on Justia Law

Appellant was convicted of two counts of statutory sodomy in the first degree. Thereafter, Appellant filed a Mo. R. Crim. P. 29.15 motion for post-conviction relief claiming that his trial counsel was ineffective for failing to object to verdict directors that allegedly violated his constitutional right to a unanimous jury verdict and for failing to hire an expert to testify at the sentencing hearing. The motion court overruled Appellant’s motion for post-conviction relief. The Supreme Court reversed, holding that Appellant established that his trial counsel was ineffective for failing to object to two insufficiently specific verdict directors, and therefore, the motion court clearly erred in denying post-conviction relief. Remanded. View "Hoeber v. State" on Justia Law