Justia Missouri Supreme Court Opinion Summaries

Defendant was charged with attempted manufacture of a controlled substance of maintaining a public nuisance. During closing arguments, the State presented to the jury a slideshow that included an enlarged color photograph of Defendant in which Defendant was wearing an orange prison jumpsuit with the words “GUILTY” superimposed in large letters running diagonally across his face. Defendant filed a motion for a new trial based on the State’s use of the altered evidence in the slideshow during closing argument. The Supreme Court vacated the trial court’s judgment and remanded for a new trial, holding that the State’s use of the altered photograph of Defendant impinged upon the presumption of innocence and the fairness of the fact-finding process, and therefore, the trial court erred in failing to grant Defendant a new trial. View "State v. Walter" on Justia Law

After a jury trial, Defendant was convicted of one count each of burglary in the first degree and an associated count of armed criminal action, attempted robbery in the first degree and an associated count of armed criminal action, assault in the third degree, and resisting arrest for a felony. The Supreme Court affirmed, holding (1) the evidence was sufficient for jury to find beyond a reasonable doubt that Defendant committed armed criminal action in connection with the burglary; (2) there was sufficient evidence to support the the resisting arrest conviction; and (3) the trial court did not err by overruling Defendant’s motion for a continuance. View "State v. Jones" on Justia Law

Respondent was arrested for driving while intoxicated and agreed to take a breath test on a breath analyzer, which measured a .172-percent blood alcohol concentration (BAC). The Director of Revenue revoked Respondent’s driving privileges based on the results of the breath test. Respondent timely filed a petition for a trial de novo, arguing that her breath test results were invalid because the breath analyzer used in her case was calibrated using only one solution. The trial court agreed with Respondent and excluded the breath test results. As a result, the court concluded that the Director failed to meet the State’s burden of providing sufficient credible evidence that Respondent drove with a BAC above .08 percent. The Supreme Court affirmed, holding that the trial court (1) correctly applied the regulation in place at the time of the breath test; and (2) correctly concluded that the Director failed to lay a proper foundation for the admission of the results of Respondent’s breath test. View "Stiers v. Dir. of Revenue" on Justia Law

A police officer searched a plastic grocery bag that Defendant was holding after he was already handcuffed and seated in the police car. Inside the bag the officer discovered heroin. Defendant was charged with the class C felony of drug possession. Defendant filed a motion to suppress evidence of the heroin, arguing that neither the arrest nor the search of his plastic bag was lawful. The circuit court overruled the motion, and Defendant was convicted. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in overruling Defendant’s motion to suppress evidence of the heroin because (1) the arrest of Defendant was lawful; and (2) the search of Defendant’s bag was not a lawful search incident to arrest, but the exclusionary rule did not apply to this case. View "State v. Carrawell" on Justia Law

Petitioner was convicted of two counts of first-degree murder for the murders to two sisters. Petitioner was sentenced to death for the murders. Petitioner filed a petition for a writ of habeas corpus in the Supreme Court, claiming that newly discovered evidence showed that the State violated Brady v. Maryland by withholding material evidence and that the Brady violation was prejudicial. The Supreme Court appointed a special master to take evidence and issue findings of fact and conclusions of law as to Petitioner’s allegation. The master eventually issued a report finding that the State had violated Brady by failing to produce evidence favorable to Petitioner and that the State’s failure to disclose this evidence was prejudicial to Petitioner. The Supreme Court adopted the master’s recommendation and vacated Petitioner’s convictions and sentences for first-degree murder, holding that substantial evidence supported the master’s findings that the State deliberately violated Brady and that the suppressed evidence, along with the totality of other evidence, showed cause and prejudice sufficient to undermine confidence in the outcome of the trial. View "State ex rel. Clemons v. Larkins" on Justia Law

Father was charged with criminal nonsupport in violation of Mo. Rev. Stat. 568.040. Father filed a motion to dismiss the information and to declare section 568.040.1 unconstitutional as a violation of his due process rights under the United States and Missouri constitutions. The trial court granted the motion and dismissed the information, concluding that the 2011 amendment to the statute, which removed the phrase “without good cause” as an element of the offense, and instead expressed it as an affirmative defense, impermissibly shifted the burden of proof to the defendant on an element of the crime. The Supreme Court reversed, holding that the statute is constitutional because due process allows a defendant to bear the burden of pleading and proving the affirmative defense of inability to provide support for good cause. View "State v. Meacham" on Justia Law

In 2013, the State charged Bob Beisly with the 2009 death of Belinda Beisley. Wilma Jean Irwin subsequently filed a wrongful death action against Beisly. Beisly moved to dismiss Irwin’s action, arguing that her claim was time-barred by Mo. Rev. Stat. 537.100, the wrongful death statute of limitations. Irwin opposed the motion, arguing that Beisly should be estopped from relying on the statute of limitations as a defense due to his fraudulent concealment of his wrongdoing. The circuit court overruled Beisly’s motion, stating that allowing Beisly to escape civil liability on the basis of the statute of limitations was “shocking to the conscience.” Beisly sought a writ of prohibition in the court of appeals. After opinion by that court, the Supreme Court granted transfer. The Supreme Court quashed the preliminary order in prohibition, holding that the doctrine of equitable estoppel foreclosed Beisly from relying on the statute of limitations as an affirmative defense due to the fraudulent concealment of his wrongdoing. View "State ex rel. Beisly v. Hon. Perigo" on Justia Law

Defendant was charged with violating the City of Moline Acres Ordinance 395.010. Defendant moved to dismiss the charge, arguing that the Ordinance and the City’s Notice of Violation contradicted state law and/or violated due process. The circuit court sustained Defendant’s motion and dismissed the charge with prejudice on the ground that the Ordinance and Notice contradicted state speeding statutes. The Supreme Court affirmed, holding that both the Ordinance and Notice are invalid because (1) the Ordinance’s rebuttable presumption that anyone driving an owner’s vehicle does so with the owner’s permission is not constitutionally permissible; and (2) the information charging Defendant is invalid because it is not supported by a notice that conforms to the requirements of Rule 37.33. View "City of Moline Acres v. Brennan" on Justia Law

Defendant was charged with three counts of unlawful possession of a firearm. Defendant filed a motion to dismiss the unlawful possession charges, claiming that the felon-in-possession law violates the Missouri Constitution’s protection of his right to bear arms. The circuit court sustained the motion. The State appealed. While the appeal was pending, the Missouri Constitution’s right to bear arms provision - article I, section 23 - was amended to state that courts must apply strict scrutiny to laws restricting the right to bear arms. The Supreme Court reversed, holding (1) the prior version of article I, section 23 applies in this case; (2) as this Court held in Doston v. Kander, strict scrutiny applies under the prior version of article I, section 23; and (3) the felon-in-possession law survives strict scrutiny and does not violate article I, section 23’s protection of Defendant’s right to bear arms. Remanded. View "State v. Merritt" on Justia Law

Plaintiffs each received notices that they had violated ordinance 66868, the City of St. Louis’s red light camera ordinance. Plaintiffs filed suit challenging the validity of the ordinance and seeking a declaratory judgment that the ordinance is invalid and an injunction prohibiting its enforcement. The City subsequently dismissed the pending prosecutions against Plaintiffs. After a bench trial, the court enjoined the City from enforcing ordinance 66868, concluding that the ordinance was invalid, but denied Plaintiffs’ petition as to the rest of the defendants. The Supreme Court affirmed, holding (1) Plaintiffs could maintain their action for declaratory judgment and injunctive relief because, after the City dismissed the prosecutions for the ordinance violations, Plaintiffs no longer had an adequate legal remedy; (2) ordinance 66868 is constitutionally invalid because it creates a rebuttable presumption that improperly shifts the burden of persuasion onto the defendant to prove that the defendant was not operating the motor vehicle at the time of the violation; and (3) the circuit court did not abuse its discretion in not awarding attorney’s fees. View "Tupper v. City of St. Louis" on Justia Law