Justia Missouri Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of first-degree murder. After the jury was unable to agree on punishment, the trial court conducted an independent review of the facts pursuant to Mo. Rev. Stat. 565.030.4 and imposed the death sentence. The Supreme Court affirmed the conviction and sentence, holding (1) any errors in the preparation of the trial transcript did not impede adequate appellate review and were not prejudicial; (2) the trial court did not err in its evidentiary rulings or in its instructions to the jury; (3) section 565.030.4 is not unconstitutional; (4) the trial court did not commit plain error in failing to hold a hearing regarding alleged the improper influence of a certain juror during jury deliberations; and (5) the death sentence in this case was proportional to the strength of the evidence.View "State v. Shockley" on Justia Law

In 2004, a jury found Appellant guilty of first-degree sodomy. Appellant was sentenced to twelve years in prison. The court of appeals affirmed the conviction. In 2009, more than four years after the deadline to file a Mo. R. Crim. P. 29.15(b) motion for post-conviction relief had passed, Appellant filed a Rule 29.15 motion. In his motion, Appellant claimed that his failure to comply with the filing deadline should be excused because the counsel he retained to draft and file his Rule 29.15 motion for him had misunderstood the deadlines. The motion court granted Appellant’s motion for leave to file his Rule 29.15 motion out of time, concluding that Appellant’s failure to comply with the filing deadline rested entirely with Appellant’s counsel. After an evidentiary hearing on Appellant’s substantive claims, the motion court granted relief and vacated Appellant’s conviction. The Supreme Court reversed and dismissed Appellant’s motion with prejudice, holding that the motion court erred by proceeding on Appellant’s untimely motion because Appellant waived all claims for relief when he failed to timely file his Rule 29.15(b) motion, and none of the exceptions to the deadline requirement applied in this case. View "Price v. State" on Justia Law

After a jury trial, Defendant was convicted of involuntary manslaughter in the first degree and armed criminal action. Defendant subsequently filed a petition for a writ of habeas corpus, claiming that the trial court's practice of permitting qualified jurors to opt out of jury service by agreeing to perform community service constituted a fundamental and systemic failure to comply with the statutory jury selection requirements. The circuit court and court of appeals denied the motion. Defendant then filed his writ petition with the Supreme Court. The Supreme Court denied the petition, holding that allowing five prospective jurors to opt out of service during Defendant's trial did not constitute a "substantial failure" to comply with the jury selection statutes or undermine the confidence in the verdict.View "State ex rel. Sitton v. Norman" on Justia Law

After a jury trial, Defendant was found guilty of twenty-six counts of first-degree murder, burglary, and related crimes for actions he took during a robbery and home invasion when he was sixteen years old. The trial court sentenced Defendant to life in prison with no possibility of parole for first-degree murder. The circuit court dismissed four counts on which the jury had found Defendant guilty, finding it had no jurisdiction over the charges because they were outside the scope of the juvenile court's certification. The Supreme Court held, inter alia, (1) the trial court erred in dismissing the four counts related to one of the victims of Defendant's crimes because she was not named in Defendant's juvenile petition; (2) the evidence at trial was sufficient to prove first-degree murder; and (3) Defendant's sentence of life without parole for first-degree murder violated the Eighth Amendment because it was imposed with no individualized consideration of the myriad of factors discussed in Miller v. Alabama. Remanded for resentencing. View "State v. Nathan" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder, first-degree robbery, and two counts of armed criminal action for shooting a killing a victim during the second of two robberies he committed when he was seventeen years old. The trial court sentenced Defendant to life in prison without the possibility of parole for murder. The Supreme Court affirmed, holding (1) the trial court did not reversibly err in playing Defendant's videotaped interrogation at trial; and (2) Defendant's sentence of life without parole violated the Eighth Amendment because it was imposed without any opportunity for the sentencing court to consider whether this punishment was appropriate in light of Defendant's age, maturity, and other factors discussed in Miller v. Alabama. Remanded.View "State v. Hart" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to death. Defendant subsequently filed a motion for post-conviction relief. The motion court denied the motion after an evidentiary hearing on five of Defendant's fourteen allegations of error. The supreme Court affirmed, holding, among other things, that the motion court did not clearly err in (1) denying Defendant's claim that his trial counsel were ineffective for failing to investigate and present a diminished capacity defense; (2) failing to find the State committed a Brady violation; and (3) failing to find Defendant's trial counsel were ineffective for failing to object to the admission of a reenactment video without an evidentiary hearing.View "Johnson v. State" on Justia Law

Defendant pleaded guilty to two counts of failure to register as a sex offender pursuant to a plea agreement. After judgment was entered, Defendant filed a timely amended post-conviction motion seeking to vacate the judgment against him, contending that his plea counsel was ineffective and that the plea and sentencing court erred. Defendant’s post-conviction counsel subsequently withdrew from the case, and a second appointed lawyer filed a late second amended post-conviction motion. The circuit court overruled Defendant’s second amended motion without an evidentiary hearing, concluding that the record refuted Defendant’s claims. The Supreme Court affirmed, holding (1) the arguments raised in the late-filed second amended motion were time-barred; and (2) the motion court did not err in finding that Defendant was not entitled to a hearing on the claims raised in his first amended motion because the claims were refuted by the record. View "Stanley v. State" on Justia Law

In two separate underlying criminal cases, Defendants each received a suspended imposition of sentence and were placed on probation. When Defendants violated the conditions of their probation, the trial court suspended probation and scheduled revocation hearings. The court, however, did not issue a ruling at the hearings but continued to conduct case reviews until after each Defendant’s probation term ended. Defendants each sought a writ of prohibition to prevent the trial court from holding probation revocation hearings after their probation terms ended. The cases were consolidated for opinion. The Supreme Court made its preliminary writs permanent, holding that, in each case, the trial court did not have the authority to hold revocation hearings after Defendants’ probation terms ended because it did not make every reasonable effort to hold the hearings during the probation terms pursuant to Mo. Rev. Stat. 559.036.8. View "State ex rel. Strauser, Relator v. Judge Martinez" on Justia Law

After a jury trial, Defendant was convicted of two counts of sexual misconduct involving a child pursuant to Mo. Rev. Stat. 566.083 and two counts of attempted sexual misconduct involving a child. The convictions arose from incidents in which Defendant knowingly exposed his genitals to young girls from the front door or window of his house. Defendant appealed, arguing (1) section 566.083 is unconstitutionally overbroad because it infringes on activities protected by Fifth and Fourteenth Amendments, (2) the statute is unconstitutional as applied, and (3) insufficient evidence supported his convictions. The Supreme Court affirmed, holding (1) because Defendant failed to show how section 566.083 serves to discourage citizens from engaging in protected speech, Defendant failed to demonstrate that the statute is overbroad; (2) section 566.083 is constitutional as applied to Defendant; and (3) the evidence presented at trial was sufficient for a jury to convict Defendant of the crimes beyond a reasonable doubt.View "State v. Jeffrey" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to life imprisonment. The court of appeals affirmed Defendant's conviction and denied her motion for post-conviction relief. Approximately thirteen years later, Defendant filed a motion to re-open her post-conviction proceedings, claiming that she had been abandoned by her appointed counsel and that her conviction should be vacated to correct a manifest injustice. The motion court denied Defendant relief, finding that Defendant's motion was a prohibited successive motion. The Supreme Court affirmed after directing attorneys in such situations to file a motion for post-conviction relief due to abandonment, holding that the motion court did not clearly err in overruling Defendant's motion, as a motion to "re-open" does not exist in the Court's rules.View "Eastburn v. State" on Justia Law