Justia Missouri Supreme Court Opinion Summaries

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

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

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

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

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