Justia Missouri Supreme Court Opinion Summaries

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

Appellant pleaded guilty to two felony counts of first-degree statutory sodomy. Appellant subsequently filed a Mo. R. Crim. P. 24.035 motion for post-conviction relief. The motion court appointed post-conviction counsel to represent Appellant in the proceeding. Appointed counsel then filed a motion requesting that the appointment of counsel be rescinded on the basis that Appellant’s Rule 24.035 motion was untimely. Without holding an independent inquiry, the motion court rescinded its previous order appointing counsel and dismissed the case with prejudice, finding that the motion was not timely filed. Thereafter, Appellant filed a motion to reopen his post-conviction proceedings, claiming that he was abandoned by his appointed counsel when his counsel failed to investigate the timeliness of his post-conviction motion before filing the motion to rescind appointment of counsel. The motion court overruled Appellant’s motion. The Supreme Court reversed, holding that the motion court clearly erred in dismissing Appellant’s motion because the record raised the presumption that Appellant was abandoned by his post-conviction counsel. View "Vogl v. State" on Justia Law

After a jury trial, Appellant was convicted of one count of child molestation and sentenced to fourteen years’ imprisonment. Appellant’s conviction was affirmed on appeal. Appellant subsequently filed a pro se motion for post-conviction relief, setting forth ten allegations of error. After an evidentiary hearing, the motion court denied post-conviction relief. The Supreme Court affirmed, holding that Appellant failed to establish that his trial counsel and appellate counsel were ineffective for failing to challenge the molestation verdict directors, as Appellant’s claims of error were either waived or without merit. View "Mallow v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of statutory sodomy in the first degree. On appeal, Appellant argued that there was insufficient evidence to convict him because the victim’s testimony was contradictory and lacked corroboration. Appellant’s argument was based on the “corroboration rule” and the “destructive contradictions” doctrine. The Supreme Court abolished the corroboration rule and the destructive contradictions doctrine because both require appellate courts to engage in credibility determinations that are properly left to judges and juries sitting as triers of fact. The Court then affirmed the judgment of conviction, holding that there was sufficient evidence to support the jury’s finding that Appellant committed statutory sodomy. View "State v. Porter" on Justia Law

John C. Middleton, an inmate under a sentence of death, was scheduled to be executed on July 16, 2014. After Middleton’s execution was scheduled to occur, Middleton field a petition for a writ of habeas corpus asserting that his execution would violate the Eighth Amendment because he was incompetent to be executed. The Supreme Court denied Middleton’s habeas petition on the merits because Middleton failed to make a substantial threshold showing that he lacked the competence to be executed and therefore was not entitled to a full hearing to determine his competence. View "Middleton v. Russell" on Justia Law

Defendant was charged with second-degree trafficking and resisting arrest. Defendant’s first trial ended in a mistrial. After a retrial, Defendant was found guilty of the charges. On appeal, Defendant argued, among other things, that the trial court lacked the authority to retry him after the end of the court term following the term in which his earlier trial ended in a mistrial. The Supreme Court affirmed Defendant’s conviction for resisting arrest and vacated Defendant’s conviction for second-degree trafficking, holding (1) the trial court had the authority to retry Defendant after the deadline had passed because Defendant failed to assert that deadline when it was still possible for the trial court to comply; (2) the trial court erred in not giving Defendant’s requested instruction regarding possession as a lesser included offense of second-degree trafficking; and (3) the evidence was sufficient to support Defendant’s conviction for resisting arrest. View "State v. Pierce" on Justia Law

After a jury trial, Defendant was found guilty of robbery in the first degree and armed criminal action. On appeal, Defendant argued that the trial court erred in refusing his request to instruct the jury on the lesser included crime of second-degree robbery. The trial court reasoned that a lesser included offense instruction was not required because there was no basis in the evidence for a reasonable juror to determine that the victim did not reasonably believe that Defendant was holding a gun to her back during the robbery. The Supreme Court vacated Defendant’s judgment of conviction as to both counts, holding (1) a trial court cannot refuse a defendant’s request for a “nested” lesser offense instruction based solely on its view of what evidence a reasonable juror must believe or what inferences a reasonable juror must draw, as the jury’s right to disbelieve the evidence and its right to refuse to draw needed inferences is a sufficient basis for a jury to conclude that the state has failed to prove the differential element; and (2) in this case, there was a basis in the evidence for the jury to find that the victim did not reasonably believe Defendant held a gun on her. Remanded. View "State v. Jackson" on Justia Law