Justia Missouri Supreme Court Opinion Summaries

Defendant pleaded guilty to two counts of stealing property of a value of more than $500. As part of the plea agreement, Cooper waived his right to file any future motion for post-conviction relief under Mo. R. Crim. P. 24.035 in exchange for the State recommending a fifteen-year sentence on each count to run concurrently with a suspended execution of the sentences and a five-year probationary term. The circuit court rendered judgment and sentences in accord with the plea agreement. After Defendant violated the terms of his probation, his fifteen-year sentences were ordered executed. Defendant subsequently filed a Rule 24.035 motion for post-conviction relief, alleging that defense counsel was ineffective. The motion court overruled the motion on the merits. The Supreme Court vacated the motion court's judgment, holding that Defendant knowingly, voluntarily, and intelligently waived his post-conviction rights. Remanded with instructions to dismiss Defendant's post-conviction motion. View "Cooper v. State" on Justia Law

Ashley Morse was arrested for driving while intoxicated. The Director of Revenue administratively suspended Morse's license for ninety days. Morse completed the suspension as well as the other requirements for reinstatement of her license, including completing a substance abuse traffic offender program, showing proof of liability insurance coverage, and paying reinstatement fees. Morse was later convicted for DWI after violating the conditions of her probation. The Director informed Morse that her driving privileges would again be suspended Morse once more had to complete the requirements for reinstatement of her license. The district court granted Morse's petition for de novo review and entered a judgment in favor of Morse, concluding that Morse's first administrative suspension had to be credited against the second administrative suspension pursuant to Mo. Rev. Stat. 302.525.4 because both suspensions arose from the same occurrence. The Supreme Court reversed in part, holding that the trial court erred in holding that giving Morse credit for her first period of suspension eliminated her obligation to offer proof of insurance and to pay reinstatement fees to obtain reinstatement of her driver's license. View "Morse v. Dir. of Revenue" on Justia Law

The State filed a felony complaint charging Melvin Davis, a registered sex offender, with violating Mo. Rev. Stat. 566.150 for knowingly being present within 500 feet of a public park that contains playground equipment or a public swimming pool. Davis moved to dismiss the complaint on the ground that section 566.150 was unconstitutional as applied to him because it violated the prohibition against retrospective laws in Mo. Const. art. I, 13. The trial court dismissed the complaint against Davis, holding that because the statute was not enacted until after Davis's original guilty plea, the statute placed a new disability on Davis based on a prior conviction and, therefore, was unconstitutionally retrospective in operation. On appeal, the State argued the constitutional prohibition against retrospective laws in art. I, 13 did not apply to section 566.150 because it was criminal in nature and the prohibition applied only to civil statutes. The Supreme Court affirmed, holding that the State's issue on appeal was not properly preserved for appellate review. View "State v. Davis" on Justia Law

William Foster was convicted of capital murder, first-degree robbery, and armed criminal action. Many years later, the department of corrections informed Foster that any funds deposited into his prison account to pay for college correspondence courses or an attorney would be subject to seizure by the state, pursuant to the Missouri Incarceration Reimbursement Act (MIRA). Foster filed a petition for declaratory judgment seeking a declaration that MIRA could not be applied to require reimbursement from him for the cost of his incarceration because the criminal acts that resulted in his incarceration were committed prior to the law's enactment. The trial court dismissed Foster's petition. The Supreme Court affirmed, holding that the facts alleged in Foster's petition were not developed sufficiently to give rise to a ripe controversy because the petition did not allege that Foster would receive sufficient assets to trigger the state's authority to seek reimbursement under MIRA. View "Foster v. State" on Justia Law

Kasim Faruqi was convicted for attempted enticement of a child. Faruqi appealed, arguing (1) the trial court erred in overruling his motion to dismiss the indictment because the statute setting forth the crime of enticement of a child was unconstitutionally vague, (2) the statements he made to a detective should have been suppressed as involuntary because they were procured by false statements that rose to the level of implied threats, and (3) the evidence discovered on his work computer should have been suppressed because it was discovered as a result of an unlawful search and seizure. The Supreme Court affirmed the judgment of the trial court, holding (1) Faruqi's vagueness challenge failed because the statute puts a person of ordinary intelligence on notice that, if he or she is at least twenty-one years old, attempting to entice a person younger than the age of fifteen years for the purpose of engaging in sexual conduct, regardless of whether the victim is, in fact, younger than fifteen years, is a crime; (2) Faruqi's statements were not obtained involuntarily; and (3) Faruqi's Fourth Amendment claim was barred as he maintained no subjective expectation of privacy in his work computer. View "State v. Faruqi" on Justia Law

After a jury trial, Reginald Griffin was found guilty of murder for the fatal stabbing of James Bausley and sentenced to life imprisonment without parole. Griffin filed a petition for a writ of habeas corpus, alleging that the State failed to disclose evidence that implicated another man as an alternate perpetrator and, hence, the State violated Brady v. Maryland. The circuit court denied the habeas petition. The Supreme Court granted the petition and held that Griffin met his burden of proving entitlement to habeas relief. Because Griffin showed that the nondisclosure of the evidence at issue was prejudicial for Brady purposes, he also established the prejudice necessary to overcome the procedural bar to granting him habeas relief. Accordingly, Griffin's conviction for the murder of Bausley was vacated. View "State ex rel. Griffin v. Denney" on Justia Law

Clarence Burgess was charged with discharging a firearm at a building and subsequently entered an Alford plea to the charge. In exchange for his plea and the waiver of his right to file any future post-conviction relief, the State recommended a fifteen-year sentence with a suspended execution of the sentence and a five-year probationary term. The circuit court rendered a judgment and sentence approving the plea agreement. After Burgess violated the terms of his probation, Burgess filed (1) a motion for post-conviction relief, alleging ineffective assistance of counsel, and (2) an application for a change of judge. The circuit court denied the application for a change of judge and sustained the state's motion to dismiss Burgess' motion for post-conviction relief. Burgess appealed, and the court of appeals transferred the case to the Supreme Court. The Supreme Court reversed the judgment of the circuit court, holding that (1) the court correctly overruled Burgess' application for a change of judge, but (2) failed to enter findings of fact and conclusions of law on Burgess' motion for post-conviction relief required to show that Burgess was not entitled to relief. Remanded. View "Burgess v. State" on Justia Law

Appellant Daniel Primm was convicted of four counts of second-degree statutory rape, three counts of second-degree statutory sodomy, and three counts of misdemeanor second-degree child molestation. Each count related to the acts appellant committed against his grandniece, T.B.. Appellant appealed, arguing (1) the trial court abused its discretion by admitting, over objection, evidence that appellant had committed uncharged sex crimes against T.B. and another grandniece, R.C., and had given R.C. marijuana; and (2) the evidence was insufficient to support appellant's conviction for one count of second-degree statutory rape. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in admitting the challenged evidence, and (2) there was sufficient evidence of penetration, taken together with the reasonable inferences therefrom, to support each count of statutory rape. View "State v. Primm" on Justia Law

Defendant Maura Celis-Garcia was convicted by a jury of two counts of first-degree statutory sodomy. The defendant appealed, asserting that (1) the trial court violated her constitutional right to a unanimous jury verdict because, although the state presented evidence of multiple, separate acts of hand-to-genital contact committed against her two minor daughters, the verdict directors failed to require the jury to agree to the specific acts she committed to find her guilty of a single count of statutory sodomy against each daughter; and (2) the trial court erred by overruling her objections to certain testimony by two expert witnesses because the testimony improperly vouched for the credibility of the victims, thereby invading the province of the jury. The Supreme Court reversed, holding that because the trial court failed to instruct the jury it had to agree on the same act or acts of hand-to-genital contact the defendant committed in finding her guilty of statutory sodomy, her right to a unanimous jury verdict was violated. Because the defendant's conviction was reversed on the basis of her first point, the Court did not address her second point. Remanded. View "State v. Celis-Garcia" on Justia Law

Plaintiffs Michelle Schaefer, Cindy Brandt, and Dale Price were charged with intoxication-related driving offenses, and each plaintiff had prior convictions for intoxication-related driving offenses. The plaintiffs filed a consolidated petition for a declaratory judgment, asserting that the provisions of Mo. Rev. Stat. 577.023 that pertain to enhanced penalties for individuals with multiple prior convictions for intoxication-related driving offenses violate the Missouri Constitution. The circuit court dismissed the petition. The Supreme Court affirmed, holding that, pursuant to the Declaratory Judgment Act, each plaintiff had an adequate remedy of law. The Court concluded that an alternative remedy to a declaratory judgment action for each plaintiff would be litigating the constitutional issues in each separate criminal case. View "Schaefer, et al. v. Koster" on Justia Law