Justia Missouri Supreme Court Opinion Summaries

Larry Welch pleaded guilty to two counts of first-degree involuntary manslaughter and two counts of second-degree assault. Defendant was driving while intoxicated at the time of the offenses. Welch was sentenced to two concurrent fifteen-year terms of imprisonment on the involuntary manslaughter counts and two concurrent five-year terms of imprisonment on the assault counts, to be served consecutively to the involuntary manslaughter sentences. Welch later moved for a reduction of his sentences under Mo. Rev. Stat. 558.046, which permits a reduction of sentence only when the inmate has been convicted of an alcohol-related crime that does not involve violence or the threat of violence. The circuit court granted the motion and ordered Welch’s involuntary manslaughter sentences to be reduced to two concurrent seven-year sentences. The prosecutor filed a petition for writ of prohibition, arguing that the trial court lacked authority to reduce Welch’s involuntary manslaughter sentences. The Supreme Court granted a preliminary writ of prohibition, which it made permanent, holding that the trial court had no authority to reduce Welch’s involuntary manslaughter sentences pursuant to section 558.046 because violent conduct was a necessary component of Welch’s crime. View "State ex rel. Richardson v. Hon. Daniel R. Green" on Justia Law

Defendant was convicted of felony criminal nonsupport. Defendant appealed, arguing that the evidence was insufficient to support a finding of guilt of criminal nonsupport. The Supreme Court affirmed, holding (1) the State presented evidence as to what would constitute “adequate support”; (2) contrary to Defendant’s argument, the State must not present evidence of a lack of in-kind support - such as food, clothing, medicine, or lodging - in order to make a prima facie case of lack of support under Mo. Rev. Stat. 468.040; and (3) there was adequate evidence to make a prima facie case that Defendant failed to provide adequate support for his child. View "State v. Claycomb" on Justia Law

After a jury trial, Defendant was convicted of second-degree murder and second-degree arson. The trial court sentenced Defendant to life imprisonment for the murder. Before the jury began deliberating, the trial court excused Juror 14, who was an alternate juror. After the jury had begun deliberating, Juror 12 was excused due to health concerns, and Juror 14 was substituted for Juror 12. Defendant appealed, arguing that the trial court improperly substituted Juror 14 after deliberations had begun. The Supreme Court reversed, holding that the trial court erred by substituting a discharged alternate juror after the jury had retired to consider its verdict, and the error deprived Defendant of his statutory right to have the same twelve jurors deliberate and decide his case. View "State v. Amick" on Justia Law

After a jury-waived trial, Defendant was convicted of second-degree robbery. Defendant was sentenced as a persistent offender to ten years’ imprisonment. Defendant appealed, arguing that there was insufficient evidence to support his conviction because he did not forcibly steal the money through the use or threatened use of force. The Supreme Court affirmed, holding that there was sufficient evidence supporting the trial court’s finding that Defendant committed the crime of second-degree robbery because he forcibly stole the money by means of an actual or attempted threat. View "State v. Coleman" on Justia Law

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

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

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

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

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

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