Justia Missouri Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of first-degree murder and multiple counts of first-degree assault, forcible rape, and forcible sodomy. Appellant was sentenced to death for the murder. The Supreme Court affirmed. Appellant subsequently filed a motion for post-conviction relief pursuant to Mo. R. Crim. P. 29.15, raising a number of additional ineffective assistance of counsel claims and arguments related to suppression issues presented at trial. After an evidentiary hearing, the motion court overruled Appellant’s motion. The Supreme Court affirmed, holding that the motion court did not clearly err in overruling the entirety of Appellant’s rule 29.15 motion for post-conviction relief. View "Davis v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and multiple counts of first-degree assault, forcible rape, and forcible sodomy. Appellant was sentenced to death for the murder. The Supreme Court affirmed. Appellant subsequently filed a motion for post-conviction relief pursuant to Mo. R. Crim. P. 29.15, raising a number of additional ineffective assistance of counsel claims and arguments related to suppression issues presented at trial. After an evidentiary hearing, the motion court overruled Appellant’s motion. The Supreme Court affirmed, holding that the motion court did not clearly err in overruling the entirety of Appellant’s rule 29.15 motion for post-conviction relief. View "Davis v. State" on Justia Law

After a jury-waived trial, Defendant was convicted of recklessly exposing another to HIV without that person’s knowledge and consent pursuant to Mo. Rev. Stat. 191.677. Defendant was sentenced to seven years’ imprisonment. Defendant appealed, arguing that, by compelling her to disclose to potential sexual partners that she has HIV, section 191.677 infringes on her constitutional rights to free speech and privacy. The Supreme Court affirmed, holding (1) although section 191.677 may compel individuals with HIV to disclose that they have HIV under certain circumstances, the statute imposes only incidental burdens on speech and does not violate constitutional provisions protecting the freedom of speech; and (2) because section 191.677 does not criminalize consensual, non-harmful sexual conduct, Defendant’s right to privacy argument fails. View "State v. S.F." on Justia Law

Defendants were charged with unlawfully possessing a firearm in violation of Mo. Rev. Stat. 571.070.1, which prohibits nonviolent felons from possessing firearms. Defendants had been convicted previously of nonviolent felonies. While the charges against Defendants were pending, voters approved Amendment 5 to Mo. Const. art. I, 23. Defendant moved to dismiss the unlawful possession charge, alleging that amended article I, section 23 does not permit the State to criminalize a nonviolent felon’s possession of a firearm. The trial courts in both cases applied the amended version of article I, section 23, concluding that section 571.070.1 was unconstitutional as applied to Defendants, and dismissed the charges. The Supreme Court reversed the judgments in both cases, holding that article I, section 23, as in effect at the time of Defendant’s alleged crimes, did not prohibit the State from regulating the right of nonviolent felons to bear arms. View "State v. Lomax" on Justia Law

Defendant was charged with unlawful possession of a firearm in violation of Mo. Rev. Stat. 571.070.1(1), which prohibits nonviolent felons from possessing firearms. Defendant had been convicted previously of the nonviolent felony of unlawful use of a weapon. Defendant moved to dismiss the unlawful possession charge, arguing that section 571.070.1 violates the right to bear arms set forth in Mo. Const. art. I, 23. The trial court agreed with Defendant and dismissed the firearms possession count. The Supreme Court reversed, holding that the Missouri Constitution does not prohibit the legislature from restricting nonviolent felons’ right to possess firearms and that the statutory bar is valid. Remanded. View "State v. Clay" on Justia Law

In 1973, Appellant pleaded guilty to felony forgery. In 1975, Appellant was discharged from probation pursuant to Mo. Rev. Stat. 549.111.2, which provided that individuals discharged from probation were “restored all the rights and privileges of citizenship.” In 1977, the statute was repealed. In 2013, Appellant applied for a concealed carry permit. The county sheriff denied the application due to Appellant’s 1973 felony forgery conviction. The circuit court affirmed, concluding that Appellant’s prior guilty plea rendered him ineligible for a concealed carry permit pursuant to Mo. Rev. Stat. 571.101, which expressly limits the availability of a concealed carry permit to individuals who have “not pled guilty to…a crime punishable by imprisonment for a term exceeding one year.” The Supreme Court affirmed, holding that section 571.101 is not unconstitutionally retrospective and that Appellant had no vested right to a concealed weapon permit. View "Hill v. Boyer" on Justia Law

Defendant was charged with first degree assault and an associated armed criminal action count under Mo. Rev. Stat. 571.015.1. Defendant, who was a juvenile at the time of the offenses, moved to dismiss the armed criminal action charge on the ground that the application of the sentencing provisions of section 571.015.1 to juvenile offenders is unconstitutional. The trial court agreed with Defendant, concluding that section 571.015.1 is unconstitutional as applied to all juvenile offenders and declared unconstitutional the three-year mandatory minimum incarceration requirement for juveniles who are certified to stand trial as adults. The State subsequently filed this interlocutory appeal challenging the trial court’s determination regarding the constitutional validity of section 571.015.1. The Supreme Court dismissed the State’s appeal, holding that the State has no right to appeal this interlocutory decision under section 547.200.1, nor does the trial court’s decision constitute a final judgment from which the State is entitled to appeal under section 547.200.2. View "State v. Smiley" on Justia Law

The City of De Soto and a De Soto resident (collectively, Appellants) filed suit against the governor and attorney general (collectively, Respondents) seeking a declaratory judgment that Mo. Rev. Stat. 321.322.4 violates the prohibition against special laws contained in Mo. Const. art. III, 40. The trial court granted summary judgment in favor of Respondents. The Supreme Court reversed, holding (1) section 321.322.4 is a special law in violation of Mo. Const. art. III, 40; (2) consequently, the State was required to provide a substantial justification for enacting the statute rather than a general law; and (3) because the State offered no such evidence, entry of judgment for the State was error. View "City of DeSoto v. Nixon" on Justia Law

The Metropolitan St. Louis Sewer District (MSD) brought claims of inverse condemnation, trespass, and negligence against the City of Bellefontaine Neighbors for damages caused to MSD sewer lines during the course of a city street improvement project. The City moved to dismiss, alleging that inverse condemnation does not apply to public property and that sovereign immunity applied and had not been waived. The trial court entered judgment in favor of the City. The Supreme Court affirmed, holding that MSD failed to state an inverse condemnation claim, and sovereign immunity barred MSD’s tort claims against the City. View "Metro. St. Louis Sewer Dist. v. City of Bellefontaine Neighbors" on Justia Law

A police officer searched a plastic grocery bag that Defendant was holding after he was already handcuffed and seated in the police car. Inside the bag the officer discovered heroin. Defendant was charged with the class C felony of drug possession. Defendant filed a motion to suppress evidence of the heroin, arguing that neither the arrest nor the search of his plastic bag was lawful. The circuit court overruled the motion, and Defendant was convicted. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in overruling Defendant’s motion to suppress evidence of the heroin because (1) the arrest of Defendant was lawful; and (2) the search of Defendant’s bag was not a lawful search incident to arrest, but the exclusionary rule did not apply to this case. View "State v. Carrawell" on Justia Law