Justia Missouri Supreme Court Opinion Summaries

Appellant was found guilty by a jury of the unlawful use of a weapon pursuant to Mo. Rev. Stat. 571.030.1. Appellant appealed, arguing that the circuit court erred in overruling his motion for a judgment of acquittal because there was insufficient evidence presented at trial that the weapon was concealed and that the weapon was a functional lethal weapon. The Supreme Court granted transfer after opinion by the court of appeals. The Court then affirmed the circuit court's judgment, holding (1) the evidence was sufficient to find Appellant concealed the firearm on or about his person; and (2) section 571.030.1 does not require the State to introduce evidence of the firearm's "functionality" in order to gain a conviction for the unlawful use of a weapon. View "State v. Wright" on Justia Law

Defendant was convicted and sentenced to twelve years without probation or parole for the class A felony of trafficking drugs in the first degree. On appeal, Defendant claimed, inter alia, that the trial court erred in overruling his objection to a verdict-directing instruction because it did not require the jury to find Defendant knew of the substance's content and character. The Supreme Court reversed, holding (1) the trial court's failure to instruct the jury to find that Defendant knew the content or character of the drugs relieved the State of its burden of proving each element of the offense beyond a reasonable doubt; and (2) this failure was plain error and required the reversal of Defendant's conviction and sentence. Remanded for a new trial. View "State v. Stover" on Justia Law

The Missouri Public Defender Commission petitioned the Supreme Court for a writ of prohibition ordering the trial court to withdraw its appointment of the public defender's office to represent Defendant, alleging that the appointment violated 18 C.S.R. 10-4.010 (the rule). The rule, promulgated by the Commission, adopts a "caseload protocol" that permits a district defender office to decline additional appointments when it has been certified as being on limited availability after exceeding its caseload capacity for at least three consecutive calendar months. The trial court did not refuse to apply the rule, but rather, the trial court said it believed it had no choice but to appoint a public defender because to do otherwise would have violated Defendant's Sixth Amendment right to counsel, as the court could identify no other realistic mechanism by which to provide other counsel. The Supreme Court ordered the trial court to vacate its order, holding that the court erred by (1) determining that the Sixth Amendment requires appointment of counsel without regard to whether counsel would be able to offer competent representation; (2) failing to apply the rule; and (3) holding that the rule provides no realistic alternative mechanisms for handling the issue of excessive appointments. View "State ex rel. Mo. Pub. Defender Comm'n v. Circuit Court" on Justia Law

David Miller was convicted of six sexual offenses against his minor daughter and was sentenced to terms of imprisonment. The Supreme Court reversed the judgment with respect to Miller's convictions for first-degree statutory sodomy, deviate sexual assault, and first-degree child molestation, holding (1) there was insufficient evidence Miller committed the charged offenses of first-degree statutory sodomy and deviate sexual assault during the charged period of December 3, 2004 through December 3, 2005, and thus Defendant's double jeopardy rights were implicated; and (2) the circuit court plainly erred in submitting a verdict director to the jury allowing the jury to find Defendant guilty of the crime of first-degree child molestation for an act that was not criminal during the charged period. Affirmed in all other respects. Remanded. View "State v. Miller" on Justia Law

During Defendant's trial for assault and armed criminal action she and the State jointly proffered a defense-of-others instruction to the trial court that was submitted to the jury. Defendant sought reversal of her conviction, claiming that the submission of the erroneous instruction to the jury was plain error. The Supreme Court affirmed the conviction, holding (1) Defendant waived appellate review by proffering the instruction she complained of; and (2) the Court declined to use plain error review because there was no sua sponte duty for the trial court to correct Defendant's faulty proffered instructions. View "State v. Bolden" on Justia Law

After a jury trial, Defendant was found guilty of first-degree robbery and armed criminal action. Defendant timely filed a pro se motion for post-conviction relief, claiming that his trial counsel was ineffective for not calling his codefendant in the crime (Codefendant) at trial, alleging Codefendant would have testified that Defendant did not act as Codefendant's accomplice in the robbery. The motion court granted Defendant's motion for post-conviction relief. The court of appeals reversed. The Supreme Court reversed, holding that Defendant's counsel was ineffective for failing to investigate and call Codefendant as a witness, and therefore, the motion court's judgment was not clearly erroneous. View "Smith v. State" on Justia Law

Defendant was convicted of first-degree murder, forcible rape, and armed criminal action and sentenced to death on the first-degree murder charge. Defendant's subsequent motion for post-conviction relief was overruled. The Supreme Court affirmed the motion court's denial of post-conviction relief, holding that the motion court did not (1) err in overruling Defendant's motion to disqualify the trial judge, who sentenced Defendant to death, from presiding over Defendant's post-conviction relief proceeding, as Defendant failed to establish disqualifying bias or prejudice on the part of the judge; (2) clearly err in denying Defendant's eight claims of ineffective assistance of trial counsel; and (3) err in denying an evidentiary hearing on Defendant's claim that Missouri's death penalty was unconstitutional. View "McLaughlin v. State" on Justia Law

This was the fifth action to come before the Supreme Court involving murders committed in 1996 by Carman Deck. Deck filed this Mo. R. Crim. P. 29.15 post-conviction proceeding, asserting (1) his counsel at the penalty phase of his capital murder trial was ineffective for failing to call certain witnesses and for other alleged deficient performance, and (2) the motion court erred in denying his motion for a new trial. The Supreme Court affirmed the denial of Rule 29.15 relief and the denial of Deck's request for a new trial, holding (1) the motion court did not clearly err in finding that counsel was not ineffective; and (2) Deck was not entitled to a new trial based on the trial court's alleged destruction of juror questionnaires. View "Deck v. State" on Justia Law

After a bench trial, Elton Norfolk was found guilty of one count of unlawfully carrying a concealed weapon and one count of possession of marijuana. Norfolk appealed, arguing that the circuit court clearly erred in overruling his motion to suppress evidence and his objections to the admission of evidence seized because the police officer lacked reasonable suspicion to stop him and check for a weapon. The Supreme Court affirmed the judgment of the circuit court, holding that Forfolk's Fourth Amendment rights were not violated, the evidence seized was properly admitted, and there was sufficient evidence to support the convictions. View "State v. Norfolk" on Justia Law

Zane Valentine pleaded guilty to one count of child molestation in the first degree and three counts of statutory sodomy in the second degree. The plea agreement provided that Valentine would be placed in the Sex Offender Assessment Unit (SOAU), and the circuit court stated it would retain jurisdiction over Valentine for 120 days while he was assessed. The circuit court then sentenced Valentine. The SOAU later recommended the circuit court grant Valentine probation. More than 120 days after Valentine was sentenced the circuit court entered an order denying Valentine's release on probation. On reconsideration, the circuit court found that Valentine had not completed a "program" as defined in Mo. Rev. Stat. 559.115, and therefore, the court had authority to deny Valentine probation after the statutory time limits set forth in the statue had passed. The Supreme Court granted Valentine a writ of mandamus and ordered the circuit court to release Valentine on probation, holding (1) the SOAU is a 120-day program under section 559.115; and (2) therefore, the circuit court abused its discretion by denying Valentine's release on probation when the order was entered beyond the statutory time limits set forth in section 559.115. View "State ex rel. Valentine v. Circuit Court (Orr) " on Justia Law