Justia Missouri Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of first-degree murder, armed criminal action, first-degree burglary, and unlawful possession of a firearm by a felon. Defendant was sentenced to death for the murder charge. The Supreme Court affirmed, holding (1) even assuming the police violated Defendant’s Fourth Amendment rights, evidence seized from Defendant’s person and car was admissible because Defendant’s flight and the nature of the alleged violation purged the evidence of any taint of an illegal stop; (2) there was sufficient probable cause to support a search warrant for Defendant’s apartment; (3) evidence of other weapons and ammunition unrelated to the crime was relevant and therefore admissible; (4) the victim’s statements on an application for a protective order and to her landlord about Defendant were admissible under the forfeiture by wrongdoing doctrine; (5) a note found in Defendant’s car was authenticated by circumstantial evidence; (6) there was sufficient evidence to support Defendant’s conviction for first-degree burglary; and (7) Defendant’s sentence was proportional. View "State v. Hosier" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree statutory sodomy, two counts of second-degree statutory sodomy, and one count of attempted first-degree child molestation. The Supreme Court reversed, holding (1) one juror committed misconduct by intentionally withholding material information related to the lawsuit, specifically that the juror formed an opinion about Defendant’s guilt or innocence during voir dire in direct contravention of the circuit court’s instructions that he was prohibited from forming or expressing any opinion about the case; and (2) the evidence was insufficient to convict Defendant of attempted first-degree child molestation. View "State v. Ess" on Justia Law

Appellant was convicted and sentenced for two counts of first-degree murder and sentenced to death on each count. The Supreme Court affirmed the convictions and sentences. Appellant subsequently filed a pro se motion to vacate his convictions and sentences pursuant to Mo. R. Crim. P. 29.15, claiming that he received ineffective assistance of counsel at trial and that the state failed to disclose exculpatory evidence. The motion judge overruled Appellant’s motion. The Supreme Court affirmed, holding (1) Appellant’s claims relating to the disclosure and investigation of an autosomal DNA profile were not preserved for review; and (2) the motion court did not clearly err in overruling Appellant’s Brady violation claim and ineffective assistance of counsel claims. View "Dorsey v. State" on Justia Law

In 2012, St. Louis County adopted an ordinance that implemented a foreclosure mediation program requiring lenders to provide residential borrowers an opportunity to mediate prior to foreclosure. Two bankers filed suit against the County seeking a declaratory judgment establishing that the ordinance was invalid. The circuit court sustained the County’s motion for summary judgment, concluding that the County possessed the charter authority to enact the ordinance, the ordinance was a valid exercise of the County’s police power, the ordinance was not preempted by state law, and the fees associated with the ordinance did not violate the Hancock Amendment. The Supreme Court reversed, holding that the ordinance was void and unenforceable ab initio because the County exceeded its charter authority in enacting the ordinance. View "Mo. Bankers Ass’n, Inc. v. St. Louis County, Mo." on Justia Law

After a jury trial, Defendant was found guilty of first degree murder. Defendant was sentenced to death. The Supreme Court affirmed the conviction and sentence, holding (1) the circuit court did not err in overruling Defendant’s motion to suppress certain statements he made and physical evidence and admitting them at trial; (2) the circuit court did not abuse its discretion or make inconsistent rulings in the admissibility of evidence at the suppression hearing; (3) the evidence amply supported a first-degree murder conviction; (4) the circuit court did not abuse its discretion in overruling Defendant’s objections and admitting during trial several pieces of evidence and several crime scene and autopsy photographs; (5) the prosecutor did not commit misconduct during closing arguments; and (6) Defendant’s death sentence was proportional to the crime. View "State v. Collings" on Justia Law

Appellant pleaded guilty to two felony counts of first-degree statutory sodomy. Appellant subsequently filed a Mo. R. Crim. P. 24.035 motion for post-conviction relief. The motion court appointed post-conviction counsel to represent Appellant in the proceeding. Appointed counsel then filed a motion requesting that the appointment of counsel be rescinded on the basis that Appellant’s Rule 24.035 motion was untimely. Without holding an independent inquiry, the motion court rescinded its previous order appointing counsel and dismissed the case with prejudice, finding that the motion was not timely filed. Thereafter, Appellant filed a motion to reopen his post-conviction proceedings, claiming that he was abandoned by his appointed counsel when his counsel failed to investigate the timeliness of his post-conviction motion before filing the motion to rescind appointment of counsel. The motion court overruled Appellant’s motion. The Supreme Court reversed, holding that the motion court clearly erred in dismissing Appellant’s motion because the record raised the presumption that Appellant was abandoned by his post-conviction counsel. View "Vogl v. State" on Justia Law

After a jury trial, Appellant was convicted of one count of child molestation and sentenced to fourteen years’ imprisonment. Appellant’s conviction was affirmed on appeal. Appellant subsequently filed a pro se motion for post-conviction relief, setting forth ten allegations of error. After an evidentiary hearing, the motion court denied post-conviction relief. The Supreme Court affirmed, holding that Appellant failed to establish that his trial counsel and appellate counsel were ineffective for failing to challenge the molestation verdict directors, as Appellant’s claims of error were either waived or without merit. View "Mallow v. State" on Justia Law

John C. Middleton, an inmate under a sentence of death, was scheduled to be executed on July 16, 2014. After Middleton’s execution was scheduled to occur, Middleton field a petition for a writ of habeas corpus asserting that his execution would violate the Eighth Amendment because he was incompetent to be executed. The Supreme Court denied Middleton’s habeas petition on the merits because Middleton failed to make a substantial threshold showing that he lacked the competence to be executed and therefore was not entitled to a full hearing to determine his competence. View "Middleton v. Russell" on Justia Law

Two police officers were patrolling a high-crime area when they passed Defendant, who was riding a bicycle, and observed what appeared to be a handgun protruding from Defendant’s waistband. The officers handcuffed Defendant and then discovered that what appeared to be a gun was an Airsoft toy gun. At that point, the officers called in a warrant check and learned there was a pickup order for Defendant. A subsequent search revealed Defendant was carrying cocaine base. Defendant was charged with one count of possession of a controlled substance. Defendant filed a motion to suppress the evidence, which the trial court overruled. Defendant appealed, arguing that, although the police had reasonable suspicion to initially stop him when they saw him carrying what appeared to be a gun, they lacked reasonable suspicion to detain him further while they performed a warrant check after they discovered the gun was a toy gun. The Supreme Court affirmed, holding that the trial court did not clearly err in overruling Defendant’s motion to suppress because even after the officers learned the gun was not real, the additional circumstances surrounding the encounter gave them reasonable suspicion to continue to detain Defendant. View "State v. Lovelady" on Justia Law

After five jury trials, Appellant was eventually convicted of the 1991 murder of Gladys Kuehler and sentenced to death. The Supreme Court affirmed the conviction and sentence. Appellant timely filed a motion for post-conviction relief, raising thirteen points on appeal. The circuit court made findings of fact and entered a judgment overruling Appellant’s motion. The Supreme Court affirmed, holding (1) Appellant’s trial counsel rendered constitutionally effective assistance; (2) Appellant’s due process rights recognized under Brady v. Maryland were not violated; and (3) Appellant’s claim that the delay between his sentencing and execution violated his due process rights lacked merit. View "Barton v. State" on Justia Law