Justia Missouri Supreme Court Opinion Summaries

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

After a jury trial, Defendant was found guilty of murdering his aunt, uncle, and their granddaughter. The trial court sentenced Defendant to death on all three counts of first-degree murder. The Supreme Court affirmed, holding that the trial court did not err by (1) rejecting Defendant’s proffered jury instruction for felony murder in the second degree; (2) admitting testimony from the State’s cell phone analyst and the State’s fingerprint analyst; (3) excluding testimony and argument that another individual had motive and opportunity to commit the murders; (4) excluding evidence of a witness’s alleged bias against a potential witness; and (5) denying Defendant’s mistrial requests when the State inadvertently showed crime scene photographs of the victims. View "State v. Blurton" on Justia Law

After a jury-waived trial, Defendant was convicted of recklessly exposing another to HIV without that person’s knowledge and consent pursuant to Mo. Rev. Stat. 191.677. Defendant was sentenced to seven years’ imprisonment. Defendant appealed, arguing that, by compelling her to disclose to potential sexual partners that she has HIV, section 191.677 infringes on her constitutional rights to free speech and privacy. The Supreme Court affirmed, holding (1) although section 191.677 may compel individuals with HIV to disclose that they have HIV under certain circumstances, the statute imposes only incidental burdens on speech and does not violate constitutional provisions protecting the freedom of speech; and (2) because section 191.677 does not criminalize consensual, non-harmful sexual conduct, Defendant’s right to privacy argument fails. View "State v. S.F." on Justia Law

After a jury trial, Defendant was found guilty of second-degree murder, armed criminal action, and first-degree burglary. Defendant was sentenced to concurrent terms of life imprisonment for the second-degree murder and armed criminal action convictions. Defendant appealed, arguing, among other claims, that the trial court violated his due process rights during the penalty phase by excluding reliable witness testimony, which could have provided a basis for a jury to exonerate him of first-degree murder. The Supreme Court vacated the trial court’s judgment, holding that the trial court abused its discretion in excluding the proposed testimony, as it met the indicia of reliability and could exonerate Defendant. Remanded. View "State v. Hartman" on Justia Law

Appellant was convicted of one count of second-degree drug trafficking. Appellant appealed, challenging the sufficiency of the evidence to support his conviction and alleging trial error. The court of appeals reversed and remanded the case due to the State’s discovery violations and the circuit court’s error in refusing to grant Appellant a continuance. After a second trial, Appellant was again convicted of second-degree trafficking. On appeal, Appellant alleged that the evidence was insufficient to support his conviction and that that circuit court erred in instructing the jury. The court of appeals affirmed. The Supreme Court affirmed, holding (1) there was sufficient evidence to support Appellant’s conviction, and therefore, the circuit court did not err in overruling Appellant’s motion for judgment of acquittal; and (2) the circuit court did not plainly err in instructing the jury. View "State v. Zetina-Torres" on Justia Law

Defendants were charged with unlawfully possessing a firearm in violation of Mo. Rev. Stat. 571.070.1, which prohibits nonviolent felons from possessing firearms. Defendants had been convicted previously of nonviolent felonies. While the charges against Defendants were pending, voters approved Amendment 5 to Mo. Const. art. I, 23. Defendant moved to dismiss the unlawful possession charge, alleging that amended article I, section 23 does not permit the State to criminalize a nonviolent felon’s possession of a firearm. The trial courts in both cases applied the amended version of article I, section 23, concluding that section 571.070.1 was unconstitutional as applied to Defendants, and dismissed the charges. The Supreme Court reversed the judgments in both cases, holding that article I, section 23, as in effect at the time of Defendant’s alleged crimes, did not prohibit the State from regulating the right of nonviolent felons to bear arms. View "State v. Lomax" on Justia Law

Defendant was charged with unlawful possession of a firearm in violation of Mo. Rev. Stat. 571.070.1(1), which prohibits nonviolent felons from possessing firearms. Defendant had been convicted previously of the nonviolent felony of unlawful use of a weapon. Defendant moved to dismiss the unlawful possession charge, arguing that section 571.070.1 violates the right to bear arms set forth in Mo. Const. art. I, 23. The trial court agreed with Defendant and dismissed the firearms possession count. The Supreme Court reversed, holding that the Missouri Constitution does not prohibit the legislature from restricting nonviolent felons’ right to possess firearms and that the statutory bar is valid. Remanded. View "State v. Clay" on Justia Law

Defendant purchased two assault rifles and engaged in target practice while planning to commit a mass shooting. Defendant’s mother alerted the police. During an interview at the police station, Defendant admitted that his plan was to go to the local Walmart and start shooting at random. Defendant was convicted of attempted first-degree assault and armed criminal action. Defendant appealed, arguing, inter alia, that there was insufficient evidence that he had the purpose to commit first-degree assault and that he took a substantial step toward commission of the offense. The Supreme Court affirmed, holding (1) a reasonable fact-finder could have found that Defendant had the intent to commit first-degree assault and that Defendant’s conduct constituted substantial steps; and (2) the trial court did not err in overruling Defendant’s motion to suppress evidence of his police interview. View "State v. Lammers" on Justia Law

In 1973, Appellant pleaded guilty to felony forgery. In 1975, Appellant was discharged from probation pursuant to Mo. Rev. Stat. 549.111.2, which provided that individuals discharged from probation were “restored all the rights and privileges of citizenship.” In 1977, the statute was repealed. In 2013, Appellant applied for a concealed carry permit. The county sheriff denied the application due to Appellant’s 1973 felony forgery conviction. The circuit court affirmed, concluding that Appellant’s prior guilty plea rendered him ineligible for a concealed carry permit pursuant to Mo. Rev. Stat. 571.101, which expressly limits the availability of a concealed carry permit to individuals who have “not pled guilty to…a crime punishable by imprisonment for a term exceeding one year.” The Supreme Court affirmed, holding that section 571.101 is not unconstitutionally retrospective and that Appellant had no vested right to a concealed weapon permit. View "Hill v. Boyer" on Justia Law

After a jury trial, Defendant was convicted of first-degree statutory sodomy. Defendant appealed, arguing, among other things, that the trial court erred by failing to sustain his application for a change of venue under Mo. R. Crim. P. 32.03. The Supreme Court affirmed, holding (1) Defendant waived his right to a change of venue by allowing his application to languish in the case until the day before trial while affirmatively representing to the trial court that he had no pending motions in the case; (2) the State presented sufficient evidence to support the conviction; and (3) the trial court did not abuse its discretion in overruling Defendant’s motion for a continuance. View "State v. Chambers" on Justia Law