Justia Missouri Supreme Court Opinion Summaries

In March 2022, Brian Milazzo was stopped at a driver’s license checkpoint in Randolph County, Missouri. Milazzo, who was driving a pickup truck with a passenger, did not have his driver’s license but had proof of insurance on his phone. After being asked to pull over, the officers noticed the passenger was not wearing a seatbelt and refused to identify himself. The officers decided to arrest the passenger for failing to wear a seatbelt. When the passenger refused to exit the vehicle, the officers instructed Milazzo to unlock the passenger-side door multiple times. Milazzo did not comply, leading the officers to break the window to arrest the passenger. Milazzo was subsequently arrested and charged with interfering with an arrest.The Circuit Court of Randolph County overruled Milazzo’s motions for judgment of acquittal, and the jury found him guilty of interfering with an arrest. Milazzo was sentenced to 21 days in jail. He appealed the conviction, arguing insufficient evidence to support the charge, specifically that failing to unlock the door did not constitute physical interference.The Supreme Court of Missouri reviewed the case. The court held that the evidence was sufficient to support the conviction. The court interpreted the statute on interfering with an arrest to include not only affirmative acts but also omissions that hamper law enforcement. The court found that Milazzo’s refusal to unlock the door constituted physical interference as it created a material barrier to the officers’ ability to arrest the passenger. The court affirmed the circuit court’s judgment and sentence against Milazzo. View "State v. Milazzo" on Justia Law

Brian K. Heathcock was found guilty of first-degree tampering, felony resisting arrest, and tampering with a victim. In September 2018, Heathcock threw his girlfriend's cell phone out of a moving car, then drove off with her car when she exited to retrieve it. The girlfriend reported the car stolen. Heathcock was later spotted by a deputy sheriff in Warren County, leading to a high-speed chase. He was eventually found near a Walmart, where he admitted to taking the car and stealing CDs.Heathcock pleaded guilty to first-degree tampering in Montgomery County in October 2019. In November 2020, he was charged in Warren County with another count of first-degree tampering for the same vehicle incident. Heathcock moved to dismiss this count on double jeopardy grounds, but the circuit court overruled the motion. He was also charged with felony resisting arrest and tampering with a victim. A jury found him guilty on all counts, and the circuit court sentenced him to five years in prison for each count, with some sentences to be served concurrently and others consecutively. Heathcock renewed his double jeopardy objection in his motion for a new trial.The Supreme Court of Missouri reviewed the case and affirmed the circuit court's judgment. The court held that Heathcock's convictions were based on two distinct acts of tampering, as he operated the vehicle unlawfully on separate occasions. The court found that each act of operation constituted a discrete crime, and thus, did not violate double jeopardy protections. The court concluded that Heathcock's actions in Montgomery and Warren Counties were separate offenses, justifying multiple convictions. View "State v. Heathcock" on Justia Law

F.S. was found guilty by a jury of statutory sodomy of an 11-year-old victim and sentenced to five years in prison. After completing her sentence and parole, she was subjected to lifetime electronic monitoring by the Missouri Department of Corrections under section 217.735. This monitoring involves wearing an ankle bracelet that tracks her location via GPS. F.S. challenged the constitutionality of this lifetime monitoring requirement, arguing it violated her Fourth Amendment rights.The Circuit Court of Cole County upheld the constitutionality of section 217.735. During the bench trial, the court received stipulated facts, exhibits, and testimony from experts. The court found that GPS monitoring can deter recidivism among sex offenders by enforcing exclusion zones and increasing the certainty of legal repercussions. The court also noted that F.S. had not reoffended since completing parole but found that sex offenders with child victims tend to reoffend over a longer period. The court concluded that the GPS monitoring was a reasonable search under the Fourth Amendment, given F.S.'s diminished expectation of privacy as a convicted sex offender and the state's legitimate interest in protecting potential victims.The Supreme Court of Missouri reviewed the case de novo and affirmed the circuit court's judgment. The court held that F.S. failed to present particularized evidence showing that section 217.735 was unconstitutionally applied to her circumstances. The court emphasized that F.S.'s status as a female offender and her lack of reoffending did not suffice to demonstrate that the statute was unreasonable as applied to her. The court concluded that the statute did not clearly contravene any specific constitutional provision and upheld the lifetime monitoring requirement. View "F.S. v. Missouri Department of Corrections, Division of Probation and Parole" on Justia Law

A nurse at a Missouri Department of Mental Health facility assaulted Vernell Beach, a non-verbal, developmentally disabled patient. The nurse was charged with second-degree assault and armed criminal action. Beach's legal guardian sued the nurse, who did not respond to the lawsuit, resulting in a default judgment. The nurse later pleaded guilty to third-degree assault, and the attorney general withdrew from representing her. A second default judgment awarded Beach $8 million plus interest. When the state refused to pay from the State Legal Expense Fund, Beach sought a writ of mandamus in the Cole County circuit court.The Cole County circuit court granted a permanent writ of mandamus directing the state to release the funds to satisfy the judgment. However, the court did so without first issuing a preliminary order in mandamus, which is required to initiate responsive pleadings and allow the state to contest the facts and raise defenses.The Supreme Court of Missouri reviewed the case and found that the circuit court's failure to issue a preliminary order in mandamus materially affected the merits of the action. The preliminary order is essential for initiating responsive pleadings and ensuring a fair process. Consequently, the Supreme Court of Missouri vacated the circuit court's judgment and remanded the case for further proceedings consistent with its opinion. View "Beach v. Zellers" on Justia Law

In the early morning, a police officer stopped Chad Thomas for driving with a broken headlight. During the stop, Thomas exhibited unusual behavior, such as rolling down the rear window instead of the front, being unable to find his driver’s license, and acting nervously. The officer conducted a pat-down search, during which Thomas mentioned he might have a "sharp," a term the officer associated with drug use. Thomas's behavior, including blocking the officer's view and lying about having his license, led the officer to call for a canine unit, which eventually alerted to the presence of drugs.The Circuit Court of Saline County overruled Thomas's motion to suppress the evidence found during the search, concluding that the officer had reasonable suspicion to extend the stop based on Thomas's behavior. The court found that the extension of the stop was justified by Thomas's actions and the need to verify his identity and the outstanding warrant. The court admitted the evidence, and the jury found Thomas guilty of possession of a controlled substance and unlawful possession of drug paraphernalia. Thomas was sentenced to 10 years in prison.The Supreme Court of Missouri reviewed the case and affirmed the circuit court’s judgment. The court held that the officer had reasonable suspicion to extend the traffic stop based on the totality of Thomas's behavior, which included nervousness, evasive actions, and inconsistent statements. The court found that the detention and subsequent search were lawful under the Fourth Amendment, as the officer's actions were justified by reasonable suspicion of criminal activity. View "State vs. Thomas" on Justia Law

Richard Emery was convicted of four counts of first-degree murder and sentenced to death for each count. Emery admitted to killing his girlfriend K.K., her mother J.M., and K.K.'s two children, Z.K. and J.K., but argued he did not deliberate before the murders. The jury rejected this argument, finding overwhelming evidence of deliberation. Emery appealed, claiming errors in jury selection, evidence admission, the prosecutor's closing argument, and alleged religious bias by the judge.The Circuit Court of St. Charles County struck a potential juror for cause, admitted body-camera footage and testimony about Emery's shootout with police and attempted carjacking, and allowed victim impact testimony from the officers and a carjacking victim during the penalty phase. Emery's objections to these decisions were overruled. The court found the evidence of deliberation compelling, noting Emery's methodical actions before and after the murders, including his calm demeanor and attempts to escape.The Supreme Court of Missouri reviewed Emery's claims and found no abuse of discretion or plain error. The court held that the body-camera footage and testimony about the shootout and carjacking were relevant to proving deliberation and providing a complete picture of the events. The court also found that the victim impact testimony was permissible under Missouri law. The prosecutor's closing argument did not constitute improper personalization, and the judge's comments about Emery's lack of spirituality were not indicative of religious bias.The court conducted an independent proportionality review and concluded that the death sentences were not imposed under the influence of passion, prejudice, or any other arbitrary factor. The evidence supported the jury's finding of statutory aggravating circumstances, and the sentences were not excessive or disproportionate compared to similar cases. The Supreme Court of Missouri affirmed the judgment of the Circuit Court. View "State v. Emery" on Justia Law

In 1998, the defendant fatally stabbed the victim during a burglary. The victim's belongings were found in the defendant's vehicle, and two witnesses testified that the defendant confessed to the crime. In 2001, a jury convicted the defendant of first-degree murder and other charges, sentencing him to death. Over the next 23 years, the defendant's claims of actual innocence and constitutional errors were repeatedly rejected by state and federal courts.The defendant's direct appeal was denied by the Missouri Supreme Court in 2003, and his post-conviction relief appeal was denied in 2005. The federal district court initially granted habeas relief, but the Eighth Circuit reversed this decision in 2012. The U.S. Supreme Court denied certiorari in 2013. Subsequent habeas petitions and requests for DNA testing were also denied by the Missouri Supreme Court and the U.S. Supreme Court.The Missouri Supreme Court reviewed the case and affirmed the lower court's judgment. The court found no clear and convincing evidence of actual innocence or constitutional error that would undermine confidence in the original judgment. The court noted that recent DNA testing did not support the defendant's claim of innocence and that the evidence showed the killer wore gloves, which aligned with the trial testimony. The court also rejected claims of ineffective assistance of counsel and Batson violations, as these issues had been previously adjudicated and found to be without merit.The Missouri Supreme Court affirmed the circuit court's judgment, denying the motion to vacate or set aside the conviction and sentence. The court held that the defendant failed to demonstrate actual innocence or constitutional error by clear and convincing evidence. The motion for a stay of execution was overruled as moot. View "Prosecuting Attorney, 21st Judicial Circuit, ex rel. Williams v. State of Missouri" on Justia Law

In 1997, John Doe pleaded guilty to two class C felonies: deviate sexual assault in the first degree and sexual assault in the first degree. He was placed on probation for five years and registered as a sex offender under the Missouri Sex Offender Registry Act (MO-SORA). After completing probation in 2002, his criminal records were sealed. Despite this, Doe remained on the sex offender registry. Over the years, MO-SORA was amended to include more stringent requirements, such as public disclosure of registrants' information, in-person reporting, and lifetime registration for certain offenses.Doe filed a petition for declaratory and injunctive relief in the Circuit Court of St. Louis County, arguing that the amendments to MO-SORA violated his substantive due process rights and constituted an ex post facto law. The circuit court ruled against Doe on all claims, leading to his appeal.The Supreme Court of Missouri reviewed the case and affirmed the lower court's judgment. The court held that Doe has no fundamental right to privacy in the information required by the registry, as the information was already public before his records were sealed. The court found that MO-SORA is rationally related to the legitimate state interest of protecting children and public safety. Additionally, the court determined that MO-SORA is civil in nature and does not constitute a punitive ex post facto law. The court concluded that the registration requirements, including lifetime registration and in-person reporting, are not excessive and serve the non-punitive purpose of public safety. Therefore, the court upheld the constitutionality of MO-SORA's registration requirements. View "Doe v. Olson" on Justia Law

Marcellus Williams was convicted of first-degree murder and sentenced to death following a jury trial. His conviction and sentence were affirmed by the Supreme Court of Missouri, and his postconviction relief was denied. Williams sought additional DNA testing through a habeas corpus petition, which led to a temporary stay of execution and the appointment of a special master to oversee the testing. The results did not demonstrate his innocence, and his habeas petition was denied. Subsequent petitions for writs of habeas corpus and declaratory judgment were also denied.The St. Louis County prosecutor filed a motion to vacate Williams' conviction and death sentence, citing potential actual innocence based on DNA evidence, ineffective assistance of counsel, and racial discrimination in jury selection. This motion remains pending in the circuit court. Despite this, the Supreme Court of Missouri issued a warrant of execution for Williams, setting a new execution date.The Supreme Court of Missouri reviewed Williams' motion to withdraw the warrant of execution, arguing that the prosecutor's motion constituted a state postconviction motion, which should bar setting an execution date. The court found that Rule 30.30(c) only refers to postconviction motions filed by the defendant, not the prosecutor. Since Williams had already exhausted his state postconviction remedies, the court held that the execution date was properly set. The court also noted that the pending prosecutor's motion did not automatically warrant a stay of execution and that Williams had not demonstrated the necessary factors for equitable relief. Consequently, the court overruled Williams' motion to withdraw the warrant of execution. View "State v. Williams" on Justia Law

Shawn Flaherty was convicted of second-degree domestic assault and armed criminal action following a violent altercation with his wife, during which he brandished a revolver and a bullet from the weapon struck his wife in the knee. Flaherty's defense at trial was that the shooting was accidental, and his counsel requested an instruction for the lesser-included offense of second-degree domestic assault, which the jury ultimately found him guilty of. Flaherty was sentenced to seven years for the assault count and three years for the armed criminal action count, to be served consecutively. His convictions were affirmed on direct appeal.Flaherty subsequently filed a motion for postconviction relief, arguing that his trial counsel was ineffective for failing to request a lesser-included instruction for fourth-degree domestic assault. The motion court overruled Flaherty’s motion after an evidentiary hearing, finding that while his trial counsel's performance was constitutionally deficient for failing to request the instruction for fourth-degree domestic assault, this did not prejudice Flaherty.The Supreme Court of Missouri affirmed the motion court's judgment. The court found that there was sufficient evidence to support the motion court’s finding that counsel’s failure to request the lesser-included instruction for fourth-degree assault did not prejudice Flaherty. The court also noted that the motion court judge, who had also presided over Flaherty's criminal trial, was in a better position to assess the impact of the evidence on the jury and whether it was reasonably likely the jury would have been persuaded by arguments that Flaherty's acts were merely criminally negligent. View "Flaherty v. State" on Justia Law