Justia Missouri Supreme Court Opinion Summaries

Defendant was charged with first-degree murder and armed criminal action. Prior to trial, Defendant filed a motion to suppress statements he made to police after being read his Miranda rights. The trial court sustained the motion, concluding that Defendant’s statement, “I ain’t signing shit without my attorney” was an invocation of his right to counsel. The Supreme Court reversed, holding that Defendant failed to clearly and unequivocally assert his Fifth Amendment right to counsel, and even assuming Defendant’a partially invoked his right to counsel, there was no Fifth Amendment violation when the police questioned Defendant after he refused to sign a consent to search form. View "State v. Holman" on Justia Law

After a jury trial, Defendant was convicted of second-degree burglary and stealing. The convictions were affirmed on direct appeal. Thereafter, Defendant filed a petition for post-conviction relief, arguing that his counsel was ineffective for failing to request an instruction on the lesser-included offense of trespass as an alternative instruction to second-degree burglary. The circuit court overruled Defendant’s motion following an evidentiary hearing. The Supreme Court affirmed, holding that counsel’s performance did not fall below an objective standard of reasonableness under the performance prong of Strickland v. Washington and that there was no need to address the prejudice prong. View "McNeal v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree assault and armed criminal action. Defendant appealed, arguing that the trial court erred in denying his challenge during voir dire to one of the prosecutor’s peremptory strikes under Batson v. Kentucky because the prosecutor failed to offer a race-neutral explanation for striking the venireperson. The Supreme Court vacated Defendant’s convictions, holding that the trial court clearly erred in denying Defendant’s Batson challenge where the prosecutor failed to offer a reasonably specific and clear race-neutral explanation for the strike. Remanded. View "State v. Meeks" on Justia Law

After a jury trial, Defendant was convicted of burglary and four counts of stealing. Three of the four stealing counts were charged as felonies - one count for each of two firearms stolen and one count for rings stolen. The convictions stemmed from Defendant’s act of breaking into two residences and stealing items of property from each residence. The Supreme Court affirmed in part and reversed in part, holding (1) Defendant’s stealing convictions for the theft of the firearms must be classified as misdemeanors because they cannot be enhanced to felonies by the terms of Mo. Rev. Stat. 570.030.3; and (2) the trial court did not abuse its discretion in failing to grant a mistrial due to testimony regarding the composition of a photograph lineup. View "State v. Bazell" on Justia Law

After a jury trial, Appellant was convicted of first-degree statutory rape and incest. The convictions were affirmed on appeal. Appellant subsequently filed a pro se Mo. R. Crim. P. 29.15 motion for post-conviction relief. The motion contained thirteen claims and was stapled to an amended Rule 29.15 motion that raised five ineffective assistance of counsel claims. The motion court denied post-conviction relief. Appellant appealed, arguing that the motion court’s judgment did not adjudicate all of the incorporated pro se claims. The Supreme Court dismissed the appeal, holding that the motion court’s failure to adjudicate all claims in the motion resulted in the lack of a final judgment. View "Green v. State" on Justia Law

After a bench trial, Defendant was convicted of the class C felony of possession of a controlled substance and sentenced to ten years’ imprisonment as a prior and persistent offender. Defendant appealed, arguing that the evidence presented at trial was insufficient to prove beyond a reasonable doubt that he had knowledge and control over the drugs in two closed pouches. The Supreme Court agreed with Defendant and reversed, holding that the State failed to prove beyond a reasonable doubt that Defendant, with knowledge of the presence and nature of the substance, had possession of the pouches containing methamphetamine. View "State v. Clark" on Justia Law

Ryan Amorine sought a writ of prohibition to prevent the trial court from holding a probation revocation hearing after Amorine’s term of probation expired. On May 4, 2011, Amorine pleaded guilty to possession of a controlled substance and second-degree domestic assault. After accepting his guilty plea, the trial court suspended the imposition of sentence and placed Amorine on supervised probation for five years. The trial court also imposed special conditions upon Amorine, which included community service and paying court costs. In 2013, a probation violation report was filed alleging that Amorine failed to pay his court costs or report any community service hours. Amorine admitted the violation in an attachment to the probation violation report. A second probation violation report was filed in 2014, again alleging Amorine failed to pay his court costs or perform his community service hours. The trial court suspended Amorine’s probation and set the matter for a hearing. At the hearing, Amorine admitted to the violation. The court extended Amorine’s probation for an additional year. In early 2015, the Board of Probation and Parole filed a “Case Summary Report” and a “Field Violation Report.” Both documents informed the court that Amorine had an earned discharge date of July 13, 2015, and with continued supervision compliance, an optimal discharge date of April 1, 2015. Both reports also indicated that the only violation of Amorine’s probation was his failure to report any community service hours he performed and the failure to pay his court costs. However, the Field Violation Report recommended that the trial court revoke Amorine’s probation, place him on a new term of suspended execution of sentence probation, direct him to pay his court costs, and perform community service work. In 2015, the court issued an order suspending Amorine’s probation. The docket sheets reflected that the court continued and rescheduled the probation revocation hearing several times in 2015; both Amorine and the state appeared at every court date. By fall 2015, Amorine, his counsel, and the state all appeared for another probation revocation hearing, but the cause was passed again. The court continued to hold case reviews on December 15, 2015, and February 17, 2016, and scheduled the next case review for April 19, 2016. The Supreme Court concluded that the facts and circumstances in this case demonstrated "unequivocally" that it needed to exercise its discretion to issue a writ of prohibition to remedy an excess of authority. The Supreme Court concluded the trial court exceeded his authority in continuing Amorine’s probation revocation hearing indefinitely after Amorine should have been discharged. Therefore, the preliminary writ of prohibition was made permanent, and the trial court was directed to discharge Amorine from probation. View "Missouri ex rel. Ryan Amorine vs. Honorable Kelly Wayne Parker" on Justia Law

Appellant was convicted of two counts of statutory sodomy in the first degree. Thereafter, Appellant filed a Mo. R. Crim. P. 29.15 motion for post-conviction relief claiming that his trial counsel was ineffective for failing to object to verdict directors that allegedly violated his constitutional right to a unanimous jury verdict and for failing to hire an expert to testify at the sentencing hearing. The motion court overruled Appellant’s motion for post-conviction relief. The Supreme Court reversed, holding that Appellant established that his trial counsel was ineffective for failing to object to two insufficiently specific verdict directors, and therefore, the motion court clearly erred in denying post-conviction relief. Remanded. View "Hoeber v. State" on Justia Law

After a fifth jury trial, Appellant was found guilty of first-degree murder and sentenced to death. The Supreme Court affirmed the conviction and death sentence on direct appeal. Appellant later filed an amended Mo. R. Crim. P. 29.15 motion for post-conviction relief asserting six broad grounds for relief. Appellant’s public defender was subsequently permitted to withdraw as Appellant’s post-conviction motion counsel. Another public defender remained as counsel for Appellant, and two other public defenders also entered their appearance as his counsel. The circuit court overruled Appellant’s post-conviction motion, and the Supreme Court affirmed. Defendant subsequently filed a motion requesting the post-conviction court to find that he had been abandoned by his post-conviction counsel and asking for permission to supplement his amended post-conviction motion with additional claims. The motion court overruled Appellant’s motion. The Supreme Court affirmed, holding that Appellant’s postconviction counsel did not abandon him during post-conviction proceedings under Missouri’s definition of “abandonment.” View "Barton v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and multiple counts of first-degree assault, forcible rape, and forcible sodomy. Appellant was sentenced to death for the murder. The Supreme Court affirmed. Appellant subsequently filed a motion for post-conviction relief pursuant to Mo. R. Crim. P. 29.15, raising a number of additional ineffective assistance of counsel claims and arguments related to suppression issues presented at trial. After an evidentiary hearing, the motion court overruled Appellant’s motion. The Supreme Court affirmed, holding that the motion court did not clearly err in overruling the entirety of Appellant’s rule 29.15 motion for post-conviction relief. View "Davis v. State" on Justia Law