Justia Missouri Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Court affirmed the judgment of the circuit court affirming the decision of the director of revenue to suspend Defendant's driver's license pursuant to Mo. Stat. 302.505, holding that the circuit court did not err in admitting testimony that a preliminary breath test was greater than 0.08 percent or in finding that Defendant was arrested upon probable cause for an alcohol-related offense.Specifically, the Supreme Court held (1) the result of a preliminary breath test is a numerical percentage by weight of alcohol in the blood of the test person, and section 577.021.3 allows a court to admit the result as evidence of probable cause to arrest; (2) because the numerical result in this case was known to the arresting officer at the time of arrest the circuit court was allowed to consider it in determining that the officer had probable cause to arrest Defendant; and (3) the judgment was supported by substantial evidence and was not against the weight of the evidence. View "Wilmoth v. Director of Revenue" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the circuit court convicting Defendant of possessing a controlled substance, in violation of Mo. Rev. Stat. 579.015.1, and unlawfully using a weapon while in possession of a controlled substance, in violation of Mo. Rev. Stat. 571.030.1, holding that Defendant's convictions did not infringe upon his right to be free from double jeopardy.On appeal, Defendant argued that his convictions violated double jeopardy protections because they arose from the same conduct. The Supreme Court reversed, holding that no double jeopardy violation existed because the plain language of the states combined with fundamental principles of statutory interpretation clearly demonstrated the legislature's intent to authorize multiple punishments under sections 579.015 and 571.030.1(11). View "State v. Onyejiaka" on Justia Law

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The Supreme Court dismissed Juvenile's appeal of his delinquency adjudication, holding that Juvenile's appeal of the issue of whether he "knowingly and voluntarily" admitted to the conduct alleged in the juvenile officer's amended petition was untimely.The juvenile officer filed an amended petition alleging that Juvenile committed second-degree burglary, first-degree trespass, and two counts of second-degree property damage. After a restitution hearing, the juvenile division set restitution at $4,000. Juvenile appealed, seeking review of the adjudication hearing and order of disposition. The Supreme Court dismissed Juvenile's appeal, holding that the appeal was untimely. View "P.D.E. v. Juvenile Officer" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court convicting Defendant of three counts of child molestation in the first degree and three counts of statutory sodomy in the first degree, holding that Defendant was not entitled to relief on his allegations of error.In this case, the Supreme Court was required sua sponte to determine whether Defendant's appeal was timely, whether a written judgment of conviction in the proper form had been entered of record, and whether the Court was stripped of appellate jurisdiction. The Supreme Court held (1) this Court had jurisdiction of Defendant's appeal; (2) Defendant did not establish a right to a new trial on the basis of newly discovered evidence; and (3) the circuit court did not plainly error in failing sua sponte to exclude certain testimony. View "State v. Vandergrift" on Justia Law

Posted in: Criminal Law
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The Supreme Court denied Petitioner's petition seeking a writ prohibiting his execution and to appoint a special master to conduct an evidentiary hearing on his incompetency claim, holding that Petitioner did not demonstrate the required "substantial threshold showing of insanity" and that his mental illness claims were procedurally barred.On April 19, 2023, the Supreme Court issued a warrant for Petitioner's execution. One month later, Petitioner filed a petition for a writ of habeas corpus claiming that his execution would violate the Eighth and Fourteenth Amendments because he was incompetent to be executed under the standard set forth in Panetti v. Quarterman, 551 U.S. 930 (2007), and Ford v. Wainwright, 477 U.S. 399 (1986), and because he was severely mentally ill. Petitioner asked the Supreme Court to issue a writ prohibiting his execution and to appoint a special master to conduct an evidentiary hearing on his incompetency claim and filed a motion for a stay of execution while his incompetency claim was adjudicated. The Supreme Court denied Petitioner's habeas petition and overruled as moot his accompanying motion for a stay of execution, holding that Petitioner did not demonstrate the substantial threshold showing of insanity required by Panetti and Ford. View "State ex rel. Johnson v. Vandergriff" on Justia Law

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The Supreme Court issued a writ prohibiting the Honorable Steven A. Judge Privette from proceeding in the underlying proceeding initiated against Betty Grooms, the circuit clerk of Oregon County, for contempt of court, holding that Judge Privette lacked authority to hold Grooms in contempt for alleged deficiencies in complying with the court order at issue.The subject court order directed Groom to prepare a spreadsheet of court costs assessed in criminal cases after local sheriff departments alleged that they had not received reimbursement for costs incurred incarcerating individuals in their county jails. Judge Privette subsequently ordered Grooms to show cause why she should not be held in contempt of court. The Supreme Court granted a writ of prohibition requested by Grooms, holding that Judge Privette lacked authority to hold Grooms in contempt for her alleged deficiencies in complying with the court order. View "State ex rel. Grooms v. Honorable Privette" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court convicting Defendant of one count of kidnapping in the first degree and one count of committing violence against an employee of the Department of Corrections, holding that there was no plain error in the proceedings below.On appeal, Defendant argued that the circuit court erred in failing to conduct a sufficient Faretta hearing to ensure his waiver of counsel was knowing, intelligent, and voluntary and in ordering his sentence to consecutively to his prior sentence, in violation of his plea agreement with the State. The Supreme Court affirmed, holding (1) Defendant failed to demonstrate that the circuit court plainly erred in sustaining Defendant's request to represent himself; and (2) the circuit court did not err in ordering Defendant's sentences to run consecutively. View "State v. Teter" on Justia Law

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In 1995, MacColl, charged with having “deviate sexual intercourse with an unnamed juvenile female,” pleaded guilty to sexual misconduct, a class A misdemeanor. The circuit court sentenced MacColl to one year in jail, suspended the execution of her sentence, and placed her on two years’ probation. MacColl completed required sexual offender treatment programs; the circuit court discharged MacColl from probation in 1997.In 2000, Boone County sheriff’s office personnel advised MacColl to register as a sexual offender under the Missouri Sex Offender Registration Act (MO-SORA) MacColl registered as a sex offender and has maintained her registration. In 2020, MacColl sought removal from the registry, arguing that she does not have a prior or current independent obligation to register under the Sex Offender Registration and Notification Act, 34 U.S.C. 20901 (SORNA) The circuit court found MacColl was required to register in 1995 because the offense to which she pleaded guilty was a sex offense against a minor as defined by the federal Jacob Wetterling Act (SORNA's predecessor); MacColl was required to register under MO-SORA beginning in 2000 because she was someone who has been required to register under federal law.The Missouri Supreme Court reversed. A genuine issue of material fact exists regarding whether the sex offender treatment programs MacColl completed during her probation qualified as a program certified by a jurisdiction or the attorney general to entitle her to a reduction in her registration period, which would resolve whether MacColl ever was required to register. View "MacColl v. Missouri State Highway Patrol" on Justia Law

Posted in: Criminal Law
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The Supreme Court vacated the judgment of the circuit court denying Defendant's pro se motion for postconviction relief filed under Mo. R. Crim. P. 24.035, holding that remand was required for the motion court to make a factual finding so it may determine whether Defendant's pro se motion was timely filed.Defendant pleaded guilty to two charges of driving while intoxicated, one in Laclede County and one in Dallas County. No written judgment was entered in the Dallas County case until when Defendant was found to have violated the probation conditions in that case. Defendant's sentence in the Dallas County case was then executed. Thereafter, Defendant filed his pro se motion for postconviction relief, which the motion court denied. The court of appeals remanded the case. Before the Supreme Court the State argued that Defendant's case must be dismissed because his original pro se motion was filed out of time. The Supreme Court remanded the case, holding that a factual finding was required as to when Defendant was first delivered to the Department of Corrections on the Dallas County case so it may be determined on the basis of that fact whether Defendant's postconviction motion was timely filed. View "Hatmon v. State" 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 two counts of first-degree statutory sodomy and one count of first-degree child molestation, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued, among other things, that the circuit court committed plain error by proceeding to a bench trial without obtaining a sufficient waiver of his constitutional right to a jury trial. The Supreme Court affirmed, holding (1) Defendant's waiver of his right to a jury trial was constitutionally sufficient; and (2) the circuit court did not plainly err by admitting a video recording of the victim's forensic interview pursuant to Mo. Rev. Stat. 492.304. View "State v. Hilbert" on Justia Law