Justia Missouri Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of one count of first-degree statutory sodomy. Defendant appealed, arguing that the trial court erred by (1) denying his motion to disqualify the entire Newton County Prosecuting Attorney’s Office (NCPAO) due to a conflict of interest, and (2) entering a written judgment reflecting convictions of two counts of first-degree statutory sodomy when, in fact, Defendant was convicted of only one count of that offense. The Supreme Court affirmed the judgment as to one count of first-degree statutory sodomy and vacated the judgment as to the second count of first-degree statutory sodomy, holding (1) the trial court did not abuse its discretion in overruling Defendant’s motion to disqualify the entire NCPAO; and (2) because the written judgment erroneously stated that Defendant was found guilty on two counts of first-degree statutory sodomy, the written judgment must be corrected to reflect what actually occurred. View "State v. Lemasters" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder, armed criminal action, first-degree burglary, and unlawful possession of a firearm by a felon. Defendant was sentenced to death for the murder charge. The Supreme Court affirmed, holding (1) even assuming the police violated Defendant’s Fourth Amendment rights, evidence seized from Defendant’s person and car was admissible because Defendant’s flight and the nature of the alleged violation purged the evidence of any taint of an illegal stop; (2) there was sufficient probable cause to support a search warrant for Defendant’s apartment; (3) evidence of other weapons and ammunition unrelated to the crime was relevant and therefore admissible; (4) the victim’s statements on an application for a protective order and to her landlord about Defendant were admissible under the forfeiture by wrongdoing doctrine; (5) a note found in Defendant’s car was authenticated by circumstantial evidence; (6) there was sufficient evidence to support Defendant’s conviction for first-degree burglary; and (7) Defendant’s sentence was proportional. View "State v. Hosier" on Justia Law

The juvenile officer for the 10th Judicial Circuit filed an Emergency Petition for Protective Custody in the juvenile division of the circuit court after Mother denied the existence of her five-year-old son, JC. At an initial hearing, Mother appeared without JC and repeatedly testified under oath that JC did not exist. Mother subsequently surrendered JC to the juvenile officer and conceded that JC was her child. Thereafter, Mother was charged with perjury based on the false testimony she gave at the protective custody hearing. Mother moved to suppress her testimony on the ground that the conduct of the protective custody hearing violated her right to counsel and her privilege against self-incrimination. The motion was overruled, and Mother was found guilty of one count of perjury. The Supreme Court affirmed, holding (1) the trial court did not err in overruling Mother’s motion to suppress; and (2) the evidence was sufficient to prove that Mother committed perjury. View "State v. Churchill" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree statutory sodomy, two counts of second-degree statutory sodomy, and one count of attempted first-degree child molestation. The Supreme Court reversed, holding (1) one juror committed misconduct by intentionally withholding material information related to the lawsuit, specifically that the juror formed an opinion about Defendant’s guilt or innocence during voir dire in direct contravention of the circuit court’s instructions that he was prohibited from forming or expressing any opinion about the case; and (2) the evidence was insufficient to convict Defendant of attempted first-degree child molestation. View "State v. Ess" on Justia Law

When pursuing a suspect on two pending felony arrest warrants, Defendant, a deputy sheriff, made a forced entry into a residence and physically subdued and arrested the suspect. As a result of his actions, the deputy was convicted of burglary, property damage, and assault. The Supreme Court reversed all three convictions, holding (1) there was insufficient evidence to support Defendant’s conviction for first-degree burglary and second-degree property damage, and therefore, the trial court erred in failing to sustain Defendant’s motion for acquittal as to these charges; and (2) the instructions given to the jury on assault were plainly erroneous. Remanded. View "State v. Hunt" on Justia Law

After a jury trial, Defendant was convicted of two counts of felony child abuse for inflicting cruel and inhuman punishment upon his fourteen-year-old son by confining him in a small bathroom and by restricting food. Defendant appealed, arguing that there was insufficient evidence to support either conviction. The Supreme Court affirmed, holding (1) there was sufficient evidence to support Defendant’s conviction for child abuse based on food restriction; and (2) there was sufficient evidence to support a finding that Defendant subjected his son to cruel and inhuman punishment by repeatedly placing him alone in the bathroom for days at a time. View "State v. Hansen" on Justia Law

Leon Taylor was convicted of first-degree murder and first-degree robbery, among other offenses, for shooting and killing a gas station attendant in front of the attendant’s eight-year-old stepdaughter. Taylor was sentenced to death. Taylor’s half-brother, Willie Owens, who participated in the robbery but not the shooting, pleaded guilty to a robbery charge. Although Taylor designated Owens as a witness to Taylor’s execution, Owens was informed he would not be permitted to witness the execution. Taylor and Owens filed a petition for a writ of mandamus to compel Respondent, the warden and director of the correctional center, to permit Owens to witness Taylor’s execution. The Supreme Court granted the writ, holding that Taylor and Owens had a clear, unequivocal right to have Owens witness Taylor’s execution pursuant to Mo. Rev. Stat. 546.740. View "State ex rel. Taylor v. Russell" on Justia Law

Appellant was convicted and sentenced for two counts of first-degree murder and sentenced to death on each count. The Supreme Court affirmed the convictions and sentences. Appellant subsequently filed a pro se motion to vacate his convictions and sentences pursuant to Mo. R. Crim. P. 29.15, claiming that he received ineffective assistance of counsel at trial and that the state failed to disclose exculpatory evidence. The motion judge overruled Appellant’s motion. The Supreme Court affirmed, holding (1) Appellant’s claims relating to the disclosure and investigation of an autosomal DNA profile were not preserved for review; and (2) the motion court did not clearly err in overruling Appellant’s Brady violation claim and ineffective assistance of counsel claims. View "Dorsey v. State" on Justia Law

In a court-tried case, Defendant was found guilty of robbery in the second degree for robbing a bank. Defendant appealed, arguing that the trial court erred by overruling his motion for judgment of acquittal because the State did not present sufficient evidence that he used or threatened to immediately use physical force against the bank teller. The Supreme Court affirmed, holding that there was sufficient evidence that Defendant’s actions constituted a threat of immediate physical force to the bank teller for the purpose of both defeating resistance to the theft of the bank’s money and compelling its surrender. View "State v. Brooks" on Justia Law

After a jury trial, Defendant was found guilty of first degree murder. Defendant was sentenced to death. The Supreme Court affirmed the conviction and sentence, holding (1) the circuit court did not err in overruling Defendant’s motion to suppress certain statements he made and physical evidence and admitting them at trial; (2) the circuit court did not abuse its discretion or make inconsistent rulings in the admissibility of evidence at the suppression hearing; (3) the evidence amply supported a first-degree murder conviction; (4) the circuit court did not abuse its discretion in overruling Defendant’s objections and admitting during trial several pieces of evidence and several crime scene and autopsy photographs; (5) the prosecutor did not commit misconduct during closing arguments; and (6) Defendant’s death sentence was proportional to the crime. View "State v. Collings" on Justia Law