Justia Missouri Supreme Court Opinion Summaries

Craig M. Wood was convicted of abducting and murdering 10-year-old Hailey Owens in Springfield, Missouri. After eyewitnesses reported the abduction and provided Wood’s license plate number, police traced it to Wood's residence. Upon searching his home, officers found Hailey’s body in the basement, along with evidence of sexual assault and materials indicating Wood’s sexual interest in young girls. Wood was tried and found guilty of first-degree murder and sentenced to death.The Circuit Court of Greene County presided over Wood’s jury trial, entered judgment, and imposed the death sentence after the jury found multiple aggravating circumstances. The Supreme Court of Missouri previously affirmed Wood’s conviction and sentence on direct appeal in State v. Wood, 580 S.W.3d 566 (Mo. banc 2019). Wood then filed a Rule 29.15 motion for postconviction relief, arguing ineffective assistance of counsel on numerous grounds related to evidence, trial strategy, and mitigation. The motion court held an evidentiary hearing and denied the motion, finding no basis for relief.On appeal to the Supreme Court of Missouri, Wood raised 22 points concerning counsel’s performance and other alleged errors. The court reviewed whether the motion court’s findings and conclusions were clearly erroneous, applying the standard set forth in Rule 29.15(k). The Supreme Court of Missouri held that none of Wood’s claims demonstrated deficient performance or prejudice under the Strickland v. Washington standard. The court found the motion court’s factual determinations and legal conclusions were not clearly erroneous and affirmed the denial of postconviction relief. The judgment overruling Wood’s Rule 29.15 motion was affirmed. View "Wood vs. State of Missouri" on Justia Law

Richard James Johnson was charged with three moving violations in Missouri, including a class E felony charge for driving while intoxicated (DWI) as a persistent offender. The persistent offender charge was based on Johnson’s alleged prior DWI convictions on two separate occasions. Johnson argued that, under recent Supreme Court precedent, any fact that could increase the range of punishment—such as whether prior DWI convictions occurred on separate occasions—must be determined by a jury, not solely by a judge.The Circuit Court of Franklin County agreed with Johnson and dismissed the class E felony DWI charge, finding that the statute governing persistent offender status violated Johnson’s Fifth and Sixth Amendment rights by not requiring a jury determination of the “separate occasions” element. The State sought review from the Missouri Court of Appeals, which denied its writ petition. The State then sought relief from the Supreme Court of Missouri, which issued a preliminary writ of prohibition.The Supreme Court of Missouri reviewed whether section 577.023.2, which assigns the fact-finding responsibility for persistent offender status to the trial judge, is facially unconstitutional. The court held that the statute is not facially unconstitutional because it is possible for the jury to determine the relevant facts in accordance with constitutional requirements. The statute can be applied constitutionally if, after the judge’s initial finding, the jury also finds beyond a reasonable doubt that the defendant is a persistent offender. Therefore, the circuit court lacked authority to dismiss the felony charge on facial constitutional grounds. The Supreme Court of Missouri made permanent its preliminary writ of prohibition, ordering the circuit court to set aside its dismissal of the class E felony DWI charge. View "State ex rel. Catherine Hanaway vs. Hellmann" on Justia Law

Richard Neil Burkett was involved in a physical altercation with his brother-in-law at a convenience store in Texas County, Missouri. Witnesses stated that after being separated from his brother-in-law, Burkett pointed a semiautomatic handgun at him, threatened him, and pulled the trigger, although the gun did not fire. Burkett gave several inconsistent accounts to law enforcement, at first denying having a gun, then claiming self-defense, and finally admitting to pointing the gun after the fight was over. At trial, Burkett’s defense was that he never intended to harm his brother-in-law and only sought to scare him, arguing his gun was unloaded and he lacked intent to injure.The Circuit Court of Texas County conducted a jury trial, where Burkett was found guilty of first-degree assault and armed criminal action. During trial, Burkett did not request a self-defense instruction nor object to the jury instructions, and his counsel did not object to the State’s closing argument, which inaccurately stated that intent was not required for first-degree assault. Burkett’s post-trial motion did not raise these issues.The Supreme Court of Missouri reviewed Burkett’s appeal, in which he requested plain error review on two grounds: the lack of a self-defense instruction and the absence of a curative instruction after the State’s misstatement of law in closing argument. The court held that although Burkett may have injected self-defense into the case through his testimony, he failed to request the instruction or object to its absence, and his trial strategy was inconsistent with self-defense. Similarly, Burkett did not object to the State’s closing argument or request a curative instruction. The Supreme Court of Missouri exercised its discretion to decline plain error review for both claims and affirmed the judgment of the circuit court. View "State v. Burkett" on Justia Law

On February 4, 2020, Isis S. Jones engaged in a series of phone calls with D.W. while D.W. was at Victim’s apartment. After a heated argument, Victim drove D.W. to her aunt’s house, during which Jones continued calling. Near their destination, Victim heard a gunshot, stopped her car, and Jones approached the vehicle, hitting the driver’s side window with a gun. D.W. exited and fought with Jones, while Victim drove away, hearing a second gunshot. Police later observed a bullet hole in Victim’s vehicle, and Victim identified Jones as the shooter. Jones was charged with unlawful use of a weapon—specifically, the class B felony of shooting at a motor vehicle—and an accompanying charge of armed criminal action.The Circuit Court of the City of St. Louis conducted a jury trial, during which the jury was instructed to decide if Jones had shot “into” a motor vehicle, which corresponds to a class E felony, rather than “at” a motor vehicle as charged. Jones did not object to this instruction. The jury found Jones guilty of unlawful use of a weapon and armed criminal action. Jones subsequently entered into a sentencing agreement, receiving a 15-year sentence for the weapon charge (execution suspended for probation) and three years for armed criminal action. Jones appealed, arguing for the first time that the variance between the charged offense and the jury instruction led to manifest injustice due to the greater sentence imposed.The Supreme Court of Missouri reviewed Jones’ claim under Rule 30.20 for plain error, which allows discretionary review of unpreserved errors resulting in manifest injustice. The court held that Jones failed to establish substantial grounds that the circuit court committed plain error, as the distinction between shooting “at” and “into” a vehicle did not constitute a facially evident, obvious, and clear error. The court declined plain error review and affirmed the circuit court’s judgment. View "State v. Jones" on Justia Law

Law enforcement in Cass County, Missouri received a report on July 12, 2021, alleging that Israel Barrera molested a fourteen-year-old girl over several years. A subsequent medical examination confirmed that the girl had contracted trichomoniasis, a sexually transmitted disease, and she denied having any consensual sexual partners. Barrera was taken into custody on September 1, 2021, and officers initially seized a urine sample and buccal swab pursuant to a warrant. However, the urine sample was unusable, leading law enforcement to seek new warrants: one to seize another urine sample (warrant 1) and one to test that sample (warrant 2). The urine sample seized under warrant 1 tested positive for trichomoniasis.The Circuit Court of Cass County found that warrant 1 failed to establish probable cause to seize and test Barrera’s urine, and consequently suppressed the urine test results. The court also determined that the good-faith reliance exception to the exclusionary rule did not apply because the supporting affidavit was so lacking in probable cause that a reasonable officer could not rely on it. The court further found warrant 2 unnecessary, as warrant 1 authorized both the seizure and search of the urine. The state appealed this suppression order.The Supreme Court of Missouri reviewed the case and held that the issuing judge had a substantial basis to conclude that probable cause supported the application for warrant 1. The Court found that the corroborative details in the affidavit—such as medical confirmation of the STD and the victim’s denial of consensual partners—provided sufficient factual support for probable cause under a commonsense, totality-of-the-circumstances approach. Therefore, the Supreme Court of Missouri reversed the Circuit Court’s suppression of the urine test results and remanded the case for further proceedings. The Court also affirmed the finding that warrant 2 was unnecessary. View "State v. Barrera" on Justia Law

Amanda Mire was charged with driving while intoxicated. She filed two motions in the Circuit Court of Greene County: one to suppress statements she made after emergency medical personnel involuntarily administered a tranquilizing drug, and another to suppress the results of a blood test taken when she was unable to knowingly consent. After a hearing, the circuit court orally ruled in favor of Mire on both motions, finding that her statements and the blood test results should be suppressed due to her inability to knowingly and voluntarily consent while under the influence of the drug.On February 26, 2024, the circuit court entered a docket entry reflecting its ruling, which unequivocally stated that the statements made after administration of the drug and the consent to the blood draw were suppressed. The court scheduled the next setting for the case and invited Mire’s counsel to provide a written order consistent with the oral pronouncement. On March 11, the court entered a formal “judgment and order” that repeated the substance of the February 26 docket entry. The state filed its notice of appeal on March 11, identifying the March 11 order as the one being appealed.The Supreme Court of Missouri reviewed the case and determined that, under section 547.200.4, the state was required to file its notice of appeal within five days of the entry of the order suppressing evidence. The Court held that the February 26 docket entry constituted the operative order with the substantive effect of suppressing the evidence. Because the state’s notice of appeal was filed more than five days after the February 26 order, the Supreme Court of Missouri dismissed the appeal as untimely. View "State of Missouri vs. Mire" on Justia Law

The case concerns a defendant who, in July 2019, orchestrated a plan to lure a man he believed had wronged him to a house in Springfield, Missouri. The defendant rented a U-Haul van, enlisted two friends, and communicated his intent to harm the victim through text messages and conversations. On the night in question, he picked up the victim, brought him to the designated house, and later drove away with the victim, who was bound and injured. The defendant’s subsequent actions included searching online for ways to dispose of a body, coercing others to help clean the van, and attempting to destroy evidence. The victim was never seen again, and his body was not found, but his blood and personal items were recovered from the van and from a bag the defendant tried to have disposed of.After these events, the Circuit Court of Greene County tried the defendant on charges of first-degree murder and first-degree kidnapping. The jury found him guilty on both counts. At sentencing, the court orally pronounced consecutive life sentences: life without parole for murder and life with the possibility of parole for kidnapping. However, the written judgment mistakenly recorded the sentences as 999 days for each count. The defendant appealed, arguing insufficient evidence for conviction and a material discrepancy between the oral and written sentences.The Supreme Court of Missouri reviewed the case. It held that the evidence was sufficient for a reasonable jury to find the defendant guilty of both first-degree murder and first-degree kidnapping, rejecting the defendant’s arguments regarding the corpus delicti doctrine and the statutory requirements for kidnapping. The court also clarified the correct legal standard for “substantial period” in kidnapping cases. The court affirmed the convictions but remanded the case solely to correct the written judgment to match the oral pronouncement of sentences. View "State v. Winter" on Justia Law

Christopher Scott was charged with first-degree robbery, armed criminal action, and unlawful use of a weapon. After a jury trial, he was found guilty on all counts and sentenced in November 2020. The Missouri Court of Appeals affirmed his conviction, and the mandate was issued on January 19, 2022. Scott then filed a pro se Rule 29.15 motion for postconviction relief on April 11, 2022, raising three claims. A public defender entered an appearance on his behalf but did not request an extension to file an amended motion. The public defender filed an amended motion on August 4, 2022, raising six claims, including the original three. The motion court denied relief on all claims after an evidentiary hearing.The Missouri Court of Appeals reviewed the case and transferred it to the Supreme Court of Missouri. The Supreme Court of Missouri noted that the amended motion was filed late and without an extension request. The court emphasized that the deadlines in Rule 29.15 are mandatory and that the abandonment doctrine, which can excuse untimely filings, applies only to appointed counsel, not to unappointed counsel. Since the public defender was not officially appointed, the abandonment doctrine did not apply.The Supreme Court of Missouri held that the motion court should not have considered the untimely claims in the amended motion. As Scott did not challenge the denial of his original pro se claims, the court affirmed the motion court's judgment denying postconviction relief on those claims. The court concluded that the amended motion's additional claims were not properly before the motion court due to the untimely filing. Therefore, the judgment of the motion court was affirmed. View "Scott v. State" on Justia Law

Cedric Mack was charged with driving while intoxicated as a persistent offender. After a jury trial, he was found guilty and sentenced by the circuit court. Mack appealed, and the court of appeals affirmed his conviction. Subsequently, Mack filed a pro se Rule 29.15 motion for postconviction relief, which included a request for a public defender. A public defender later entered an appearance and filed an amended motion. The motion court overruled the amended motion after an evidentiary hearing. Mack appealed, and the court of appeals remanded the case for findings of fact, conclusions of law, and an abandonment inquiry. On remand, the motion court found the public defender had abandoned Mack, considered the amended motion on the merits, and denied relief again. Mack appealed.The Supreme Court of Missouri reviewed the case. The court noted that Mack's amended motion was not timely filed under the applicable version of Rule 29.15(g). The court also found that the public defender's entry of appearance without being appointed meant the abandonment doctrine did not apply. Consequently, the only issue was whether Mack's single pro se claim needed to be resolved again. The court determined it did not, as the claim had already been raised and decided in Mack's direct appeal.The Supreme Court of Missouri held that Mack's pro se Rule 29.15 motion was the only timely filed motion and contained a single claim identical to one previously rejected on direct appeal. Therefore, the judgment of the motion court denying postconviction relief was affirmed. View "Mack v. State" on Justia Law

In 2020, C.S. pleaded guilty to two charges in the Lafayette County circuit court: possession of a controlled substance for possessing more than 35 grams of marijuana, and unlawful use of a weapon for possessing a firearm while knowingly in possession of a controlled substance. He was sentenced to seven years and four years of imprisonment, respectively, but the execution of his sentence was suspended. After his probation was revoked in 2021, C.S. was incarcerated. Following the approval of Amendment 3 in 2022, which allows expungement for certain marijuana offenses, C.S. filed a petition to expunge both convictions.The Lafayette County circuit court expunged C.S.'s conviction for possession of a controlled substance but denied the petition to expunge the conviction for unlawful use of a weapon. The court reasoned that the unlawful use of a weapon is a "weapons offense" and not eligible for expungement under the Missouri Constitution's article XIV, § 2.10(7)(a)c.The Supreme Court of Missouri reviewed the case and affirmed the circuit court's judgment. The court held that the offense of unlawful use of a weapon for possessing a firearm while knowingly in possession of a controlled substance is not a "marijuana offense" within the meaning of article XIV, § 2 of the Missouri Constitution. The court concluded that the primary purpose of the statute criminalizing unlawful use of a weapon is to prevent conduct that endangers others, and therefore, it is not eligible for expungement under the constitutional provision. View "C.S. v. Missouri State Highway Patrol Criminal Justice Information Service" on Justia Law