Justia Missouri Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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In 2003, Appellant was convicted of two counts of first degree murder and sentenced to death. In 2015, Appellant filed a petition for a writ of habeas corpus, claiming that he should not be executed because he was severely mentally ill at the time he committed the crimes. The Supreme Court denied the habeas petition, holding that Appellant failed to raise any legally cognizable claim for habeas relief related to his claim that he was mentally ill at the time of the murders where (1) Appellant failed to raise his claim at trial, on appeal, or during post-conviction relief proceedings; and (2) Appellant did not make a threshold showing that his current mental condition makes him incompetent to be executed. View "State ex rel. Strong v. Griffith" on Justia Law

Posted in: Criminal Law
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Relator pleaded guilty to one count of driving while intoxicated as a chronic offender and was sentenced to five years imprisonment and participation in a long-term substance abuse treatment program. After successfully completing the treatment program, the circuit court directed that Relator be released on probation on June 8, 2015. Relator filed this petition for writ of mandamus arguing that he was entitled to immediate release on probation pursuant to Mo. Rev. Stat. 217.362.3 because he successfully completed the program. The Supreme Court denied the petition, holding that Relator’s proposed June 8, 2015 release date satisfied the requirement that he serve at least two years of imprisonment as required by statute while meeting all requirements imposed by the plain language of section 217.362.3. View "State ex rel. Hodges v. Hon. Asel" on Justia Law

Posted in: Criminal Law
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After a jury trial, Relator was found guilty of driving while intoxicated and sentenced to ten years imprisonment and participation in a long-term substance abuse treatment program. After Relator successfully completed the substance abuse program, the circuit court directed that Relator be released on probation on June 24, 2015. Relator filed this petition for writ of mandamus arguing that he was entitled to immediate release on probation pursuant to Mo. Rev. Stat. 217.362.3. The Supreme Court denied the petition, holding that Relator failed to establish a clear, unequivocal, specific right to immediate release on probation. View "State ex rel. Mammen v. Hon. Chapman" on Justia Law

Posted in: Criminal Law
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After a jury trial, Appellant was convicted of second-degree assault of a probation and parole officer. The court of appeals affirmed. Appellant subsequently filed a pro se Mo. R. Crim. P. 29.15 motion. The motion court appointed post-conviction counsel to represent Appellant in the proceeding. Ninety-one days later, Appellant’s appointed counsel filed an amended motion alleging claims of ineffective assistance of counsel. The amended motion was not timely. The motion court overruled the motion without holding an evidentiary hearing. The Supreme Court reversed because the motion court did not make an independent inquiry under Luleff v. State into whether Appellant was abandoned by appointed counsel when the untimely amended motion was filed. Remanded for an independent inquiry into whether Appellant was abandoned by appointed counsel. View "Moore v. State" on Justia Law

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In 2001, Petitioner was convicted of first-degree murder, first-degree assault, first-degree burglary, and two counts of armed criminal action. Petitioner was sentenced to death for the murder. The convictions were affirmed on appeal. In On February 25, 2015, the Supreme Court scheduled Petitioner’s execution for April 14, 2015. Petitioner filed a petition for a writ of habeas corpus, alleging that he was incompetent to be executed under Ford v. Wainwright, Panetti v. Quarterman, and Mo. Rev. Stat. 552.060.1. Petitioner asked the Supreme Court to issue a writ prohibiting his execution and to appoint a special master to conduct an evidentiary hearing to adjudicate his claim of incompetency. Petitioner also sought a stay of execution while his incompetency claim was adjudicated. The Supreme Court denied the habeas petition on the merits and overruled the accompanying motion for a stay of execution as moot, holding that Petitioner was not incompetent to be executed under Ford, Panetti, or section 552.060.1. View "State ex rel. Cole v. Griffith" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was found guilty of two counts of first-degree murder, one count of forcible rape, one count of forcible sodomy, and five counts of armed criminal action. Defendant received two death sentences for the murder convictions. The Supreme Court affirmed, holding that the trial court did not err in (1) failing to stop the trial and order a competency evaluation, as Defendant did not meet his burden of demonstrating that he was not competent to stand trial; (2) granting Defendant’s requests to not remain in the courtroom during certain phases of his trial; (3) finding Defendant voluntarily waived his right to testify during both the guilt and penalty phases of his trial; (4) overruling Defendant’s motion for a continuance to be medicated; (5) denying the jury’s request to view all of the exhibits admitted into evidence during the penalty phase; and (6) admitting victim impact testimony and evidence. Finally, the Court held that the imposition of the death penalty met the statutory requirements. View "State v. Driskill" on Justia Law

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After a jury trial, Cecil Clayton was found guilty of first-degree murder and sentenced to death. After unsuccessfully pursuing an appeal and post-conviction relief, Clayton filed a federal petition for a writ of habeas corpus, which the federal district court denied. The U.S. Supreme court affirmed that decision. On February 6, 2015, this Supreme Court scheduled the execution of Clayton. Clayton filed a petition for writ of habeas corpus claiming he was not competent to be executed under Ford v. Wainwright, Panetti v. Quarterman, and Mo. Rev. Stat. 552.060.1. The Supreme Court denied Clayton’s petition for writ of habeas corpus and overruled as moot Clayton’s accompanying motion for a stay of execution, holding (1) Clayton was competent to be executed under Ford and Panetti and met the standard for competence in section 552.060.1; (2) Mo. Rev. Stat. 552.060.2 is not unconstitutional; and (3) Clayton is not intellectually disabled under Missouri law and therefore not categorically excluded from eligibility for the death penalty. View "State ex rel. Clayton v. Griffith" on Justia Law

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Defendant was charged with murder in the first degree, assault in the first degree, and two counts of armed criminal action. On the day of trial, after the trial court denied the state’s request to reconsider granting a continuance, the state dismissed the case nolle prosequi. Later that day, the state filed a new complaint with the same charges against Defendant. Defendant filed a motion to dismiss based on a violation of his right to a speedy trial. The trial court overruled the motion to dismiss. After a trial, Defendant was convicted of the charges. The Supreme Court affirmed, holding that the trial court did not err in (1) not designating the state’s nolle prosequi as a dismissal with prejudice because the court did not have authority to do so; and (2) overruling Defendant’s motion to dismiss, as no prejudice resulted from the delay, and therefore, Defendant’s right to a speedy trial was not violated. View "State v. Sisco" on Justia Law

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After a jury trial, Defendant was found guilty of first-degree murder, first-degree assault, and two counts of armed criminal action. Defendant moved for a judgment of acquittal notwithstanding the jury’s verdict, asserting that convictions for first-degree murder and armed criminal action in connection with the murder, first-degree assault, and armed criminal action in connection with the assault violated double jeopardy. The circuit court partially granted this motion and acquitted Defendant of first-degree assault and the related armed criminal action conviction. Defendant appealed, and the State cross-appealed. The Supreme Court (1) reversed the circuit court’s judgment with respect to the assault and related armed criminal action and remanded for sentencing on the jury’s verdicts on those offenses, holding (a) the circuit court’s failure to accurately record that Defendant’s convictions resulted from trial rather than a plea of guilty was a clerical mistake that should be corrected, and (b) the circuit court erred in ruling that the murder and assault convictions violated double jeopardy; and (2) affirmed the judgment in all other respects. View "State v. Smith" on Justia Law

Posted in: Criminal Law
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When two of Price Chopper’s employees saw Deborah Barkley head for the store’s exit without paying for certain items, they confiscated the items and detained her at the store’s security office on suspicion of shoplifting. Approximately forty-five minutes after Barkley was first detained, the police arrested her and escorted her from the store. Barkley was charged with shoplifting but was later acquitted of this charge. Barkley sued Price Chopper, alleging various torts arising out of her detention. At the close of the evidence, Barkley abandoned all of her claims except false imprisonment and battery. The jury found for Price Chopper on both counts. Barkley appealed, arguing that the merchant’s privilege extends to claims of battery, and the privilege ends when the merchant’s property is recovered. The Supreme Court affirmed, holding that a merchant is privileged to detain a person in a reasonable manner and for a reasonable time if the merchant has probable cause to believe that person is shoplifting, and the merchant may continue the detention after the property is recovered to determine whether the person was actually shoplifting and to summon the police and instigate criminal proceedings. View "Barkley v. McKeever Enters., Inc." on Justia Law