Justia Missouri Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Court vacated Defendant's guilty by mental disease or defect (NGRI) plea that the circuit court accepted after finding Defendant lacked competence to continue with the criminal proceedings, holding that the circuit court exceeded its authority under Mo. Rev. Stat. 552.020.8 and violated Defendant's due process rights. Defendant was charged with first-degree robbery and armed criminal action. After accepting Defendant's NGRI plea the circuit court found Defendant lacked competence to proceed and committed him to the department of mental health. The Defendant sought a writ of habeas corpus arguing that, pursuant to section 552.020.8, upon finding him incompetent, the circuit court was required to suspend the proceedings and commit him to the department of mental health. The Supreme Court agreed, holding that, by accepting Defendant's NGRI plea despite finding him incompetent to proceed, the circuit court exceeded its authority pursuant to section 552.020.8 and violated Defendant's due process rights. View "State ex rel. Kelly v. Inman" on Justia Law

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The Supreme Court affirmed Defendant's conviction of felony possession of a controlled substance, holding that the circuit court did not err in admitting evidence obtained from Defendant's statements and a search of his vehicle after a traffic stop. On appeal, Defendant argued that the circuit court erred in overruling his motion to suppress because the traffic stop was unreasonable and violated the Fourth Amendment. The Supreme Court affirmed, holding (1) crossing the fog line and driving on the shoulder is a traffic violation and creates a lawful justification for a traffic stop; and (2) the stop in this case was justified after Defendant's vehicle crossed the fog line and drove on the shoulder and therefore did not constitute an unreasonable seizure under the Fourth Amendment. View "State v. Smith" on Justia Law

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The Supreme Court affirmed the judgment of the motion court denying Defendant's motion for postconviction relief filed under Mo. R. Crim. P. 29.15, holding that the motion court did not err in denying postconviction relief. Defendant was convicted of murder in the first degree, armed criminal action, burglary in the first degree, and unlawful possession of a firearm by a felon. The trial court sentenced Defendant to death. Defendant later moved for postconviction relief, alleging ineffective assistance of counsel. The motion court denied the postconviction motion. The Supreme Court affirmed, holding that the motion court did not err in denying Defendant's claims. View "Hosier v. State" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court convicting Defendant of one count of first-degree assault and one count of felony resisting arrest, holding that sufficient evidence supported a finding that Defendant resisted an arrest for an offense and that offense constituted a felony as a matter of law. At the close of the State's evidence Defendant moved for judgment of acquittal. The circuit court overruled the motion as to the counts at issue on this appeal. Defendant appealed, arguing that the circuit court erred in overruling his motion for judgment of acquittal on the felony resisting arrest count because there was insufficient evidence presented to support a finding of guilt. The Supreme Court affirmed, holding that the evidence was sufficient to support Defendant's conviction of felony resisting arrest. View "State v. Shaw" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the circuit court convicting Defendant of attempted enticement of a child, holding that there was no error in the proceedings below. Defendant was convicted of attempted enticement of a child, in violation of Mo. Rev. Stat. 566.161, and sentenced to five years' imprisonment. The Supreme Court affirmed, holding (1) the circuit court did not err or deprive Defendant of a fair trial in failing to submit Defendant's proffered instructions; and (2) the circuit court did not abuse its discretion in sustaining the State's objection to the cross-examination of the victim's sister, from whom Defendant sought to elicit testimony as to whether the victim had a tendency to exaggerate. View "State v. Michaud" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the judgment of the motion court to the extent it overruled Appellant's motion for postcondition relief on his driving while revoked conviction and affirmed the judgment in all other respects, holding that appellate counsel's failure to raise a sufficiency of evidence claim constituted deficient performance that prejudiced Appellant. Appellant was convicted of driving while intoxicated and driving while revoked. In his Mo. R. Civ. P. 29.15 motion for postconviction relief Appellant argued that his trial counsel was ineffective for failing to call his physician to testify that certain prescription medications he took made him appear intoxicated by alcohol the night he was arrested and that appellate counsel was ineffective for failing to argue there was insufficient evidence to enhance his driving while revoked misdemeanor to a felony. The Supreme Court agreed and reversed in part, holding (1) Appellant's postconviction relief claim relating to his driving while intoxicated conviction was properly denied because there was no reasonable probability the trial court's finding would have been different had the physician testified at Appellant's trial; and (2) appellate counsel's failure to raise the sufficiency of the evidence claim constituted deficient performance by which Appellant was prejudiced. View "Hounihan v. State" on Justia Law

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The Supreme Court affirmed the judgment of the motion court overruling Defendant's Rule 29.15 motion for post conviction relief without an evidentiary hearing, holding that Defendant failed to plead facts showing his counsel was ineffective. In his Rule 29.15 motion Defendant claimed that his trial counsel provided ineffective assistance by failing to seek suppression of methamphetamine found during a warrantless search of a cigarette pack seized from his pocket on the grounds that the search occurred thirty minutes after his arrest in an area outside his immediate control. The motion court overruled the motion. The Supreme Court affirmed, holding that the search of Defendant's cigarette was a lawful search incident to arrest, and therefore, Defendant failed to plead facts showing his counsel was ineffective in not challenging the search. View "Greene v. State" on Justia Law

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In this appeal from the circuit court's finding that D.C.M. committed an act that, if committed by an adult, would have constituted the felony of making a terrorist threat in the second degree, the Supreme Court remanded this case to the circuit court for an evidentiary hearing to determine whether counsel was ineffective and otherwise affirmed the judgment, holding that the record was insufficient to determine whether counsel was ineffective. D.C.M. was sitting in a school cafeteria when he told another student that he felt like "blowing the school up" or wanted to see how it felt to "shoot the school up." Based on this evidence, the circuit court placed D.C.M. in the custody of the division of youth services for an indefinite term. The Supreme Court held (1) D.C.M.'s ineffective assistance of counsel claims could not be addressed on direct appeal because the record was insufficient to address these claims; (2) the circuit court did not abuse its discretion in denying counsel's request for a continuance; and (3) there was sufficient evidence for the circuit court to find beyond a reasonable doubt that D.C.M. committed an act which, if committed by an adult, would have constituted the felony of making a terrorist threat in the second degree. View "D.C.M. v. Pemiscot County Juvenile Office" on Justia Law

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The Supreme Court vacated the judgment of the circuit court convicting Defendant of first-degree assault and armed criminal action, holding that the circuit court erred in failing to submit a self-defense instruction. On appeal, Defendant argued that the circuit court erred by refusing to submit a self-defense instruction. In response, the State argued that Defendant was not entitled to a self-defense instruction because Defendant denied stabbing the victim. The Supreme Court disagreed with the State, holding (1) the only relevant inquiry when a defendant requests an instruction on a theory of defense is whether, after viewing all the evidence and drawing all reasonable inferences in favor of the theory propounded by the defendant, there was substantial evidence to support the requested instruction; and (2) the circuit court erred in failing to give a self-defense instruction because there was substantial evidence to support the submission of such an instruction. View "State v. Barnett" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the circuit court finding Defendant guilty of the first-degree murder of a ten-year-old girl and sentencing him to death, holding that none of Defendant's assignments of error warranted reversal. Specifically, the Court held that the circuit court did not abuse its discretion by (1) overruling Defendant's objection to the admission of photographs from the victim's cellphone; (2) admitting gun evidence found in Defendant's home; (3) admitting the contents of a folder containing photos of Defendant's female, middle school students and accounts of fictional sexual encounters with thirteen-year-old girls; (4) admitting victim impact evidence; (5) permitting the State to argue during closing argument that the jury could speak for the victim and her family by sentencing Defendant to death; and (6) sustaining the State's motion to strike a venire person for cause during the death qualification voir dire. Further, Defendant's constitutional arguments were unavailing, and Defendant's death sentence met all the statutory requirements. View "State v. Wood" on Justia Law