Justia Missouri Supreme Court Opinion Summaries

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

Appellant Anthony Brown appealed his convictions for firearms charges and second-degree murder. At trial, Appellant claimed self-defense. During closing arguments, the trial court permitted the State to use a âpropâ gun to rebut Appellantâs self-defense argument. The State used the gun to show that the victim could not have carried and drawn the gun as Appellant had asserted. There was no evidence that the gun that was used as an exhibit in the Stateâs closing argument was similar in size or shape to the victimâs gun. During deliberations, the jury asked to see the âprop.â The trial court denied the request because the prop was not evidence. Upon review of the trial records, the Supreme Court found that the State âshould not have been able to bypass normal evidentiary limitationsâ by showing the gun to the jury: âthe Stateâs closing argument demonstration was necessarily speculative and carried with it the distinct possibility of misleading the jury . . . Under these circumstances, there is a substantial likelihood that the juryâs decision was influenced by the improper demonstration.â Accordingly, the Court reversed the trial courtâs judgment and remanded the case for further proceedings.

A jury found Appellant Donald Nash guilty of capital murder for the 1982 killing of Judy Spencer. He was sentenced to life without the possibility of parole or probation for 50 years. Appellant argued on appeal that he was wrongly convicted under a section of state law that had been repealed in 1983, and that no other statute replaced it that criminalized the murder for which he was charged. Furthermore, Appellant argued that he was convicted on insufficient evidence at trial, because the trial court excluded his evidence that someone else committed the murder. The Supreme Court was not persuaded by Appellantâs interpretation of the statute in question, finding that âthe apparent purpose of the 1983 enactment of the new section . . . was to make clear that an offense committed in 1982 should be charged and prosecuted according to the laws existing in 1982â and not after the changes were enacted. The Court also found that the evidence presented at Appellantâs trial was sufficient to support the jury verdict against him. The Court affirmed Appellantâs conviction and sentence.

Appellant Ricky Ross filed a motion challenging the constitutional validity of Missouri's second-degree statutory rape statute. He was convicted and sentenced under this statute. On the day his case was set for trial, Appellant appeared in court and announced that he wished to plead guilty to spare the victim and her family from having to go through trial. The trial court accepted Appellant's plea, and sentenced him to 10 years' imprisonment. Thereafter, Appellant sought post-conviction relief, arguing that the statute under which he was convicted was unconstitutional because it was adopted in violation of the Missouri Constitution. After an evidentiary hearing, the appellate court overruled Appellant's motion. The Supreme Court did not reach the merits of Appellant's appeal. Appellant waived his claim to challenge the statute because he did not raise the issue before he plead guilty. The Supreme Court found that the appellate court did not err in overruling Appellant's motion for post-conviction relief, and the Court affirmed the decision.