Justia Missouri Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court denying Petitioner's petition for a writ of prohibition requesting that the circuit court prohibit Respondent from determining that he must register as a sex offender, holding that Petitioner failed to establish that he was entitled to the writ.Petitioner pleaded guilty to four counts of endangering the welfare of a child. Several months later, Petitioner's probation officer notified him that he was required to register as a sex offender based on allegations in charges that the State later abandoned. Petitioner then filed this petition. The circuit court denied a permanent writ of prohibition. The Supreme Court affirmed, holding (1) the circuit court erred in using the State's abandoned charges to find Petitioner pleaded guilty to sex offenses; but (2) a writ of prohibition was not the proper remedy. View "Doe v. Frisz" on Justia Law

The Supreme Court vacated the judgment of the circuit court convicting Defendant of fifteen counts of unlawful possession of a firearm following a jury trial, holding that the circuit court committed reversible error by allowing the jury to hear a prejudicial, out-of-court statement made by a witness who never appeared or testified at trial.After Defendant was arrested on allegations of domestic violence against his wife, Beckey, Beckey told officers that Defendant illegally possessed numerous firearms. Defendant was subsequently charged with fifteen counts of unlawfully possessing a firearm. During trial, the out-of-court statement made by Beckey, who did not appear at trial, was elicited during an officer's testimony. The circuit court ruled that Beckey’s statement could be considered as substantive evidence. Defendant was subsequently convicted. The Supreme Court vacated the conviction, holding that the circuit court prejudicially erred in allowing the officer's testimony over Defendant's violation. View "State v. Hollowell" on Justia Law

The Supreme Court reversed the judgment of the circuit court finding Defendant to be a dangerous offender and remanded the case for resentencing, holding that the State failed to plead all essential facts and introduce evidence establishing sufficient facts to warrant a finding beyond a reasonable doubt that Defendant was a dangerous offender.A jury found Defendant guilty of four counts of second-degree burglary and sentenced him to a total of thirty years' imprisonment. On appeal, Defendant argued that the circuit court committed plain error in finding that he was a dangerous offender. The Supreme Court agreed and reversed Defendant's sentences, holding that the circuit court plainly erred in sentencing Defendant to sentences greater than the maximum authorized by law, resulting in manifest injustice. View "State v. Yount" on Justia Law

The Supreme Court affirmed the judgment of the circuit court determining that Mo. Rev. Stat. 595.201, as applied to defense attorneys, is constitutionally invalid and that the passage of Senate Bill 569 (SB 569) was procedurally proper, holding that the circuit court did not err in its judgment.Plaintiffs - five public defenders and three criminal defendants - brought this action for declaratory and injunctive relief challenging the constitutional validity of statutes relating to victims of sexual offenses, including SB 569 and section 595.021, which requires criminal defense attorneys to provide information to victims of sexual assault offenses. The circuit court (1) declared section 595.201 constitutionally invalid as as applied to defense counsel because it violated defense attorneys' rights to freedom of speech, and (2) rejected procedural challenges to SB 569 as a whole. The Supreme Court affirmed, holding that the circuit court properly determined that (1) section 595.201.2(4)'s requirements violate defense attorneys' free speech rights, and (2) the General Assembly complied with the procedural limitations imposed by the Missouri Constitution in passing SB 569. View "Fox v. State" on Justia Law

The Supreme Court reversed the decision of the circuit court sustaining Defendant's motion to dismiss one count of possession of a controlled substance, holding that the circuit court's decision to dismiss the possession count on double jeopardy grounds was erroneous.Defendant was charged with five counts, including the possession count and one count of unlawful use of a weapon by possessing a firearm while in possession of a controlled substance (UUW-possession), all stemming from the same incident. Defendant plead guilty to all counts except the possession count, arguing that because he had been convicted of the greater offense of UUW-possession via his guilty plea, any subsequent prosecution for possession would constitute a double jeopardy violation. The circuit court dismissed the possession count. The Supreme Court reversed, holding that the circuit court erred by dismissing the possession count against Defendant. View "State v. Andrews" on Justia Law

The Supreme Court denied the writ of prohibition sought by T.J. to dismiss the state's prosecution against him without prejudice so that the circuit court's juvenile division may adjudicate the charges against him, holding that T.J. was not entitled to the writ.The State charged T.J. in the court of general jurisdiction with committing three felony offenses when he was seventeen years old. T.J. filed a motion to dismiss, contending that the juvenile division had the exclusive authority to adjudicate the charges against him pursuant to legislation enacted in 2018. The circuit court overruled the motion. The Supreme Court affirmed, holding that the juvenile division did not have the statutory authority to adjudicate the charged offenses. View "State ex rel. T.J., v. Honorable Cundiff" on Justia Law

The Supreme Court reversed the judgment of the circuit court dismissing without prejudice the state's prosecution against R.J.G., who was alleged to have committed several felony offenses when he was seventeen years old, holding that the circuit court erred in dismissing the state's prosecution in the court of general jurisdiction.The state charged R.J.G. with felony offenses in a court of general jurisdiction. R.J.G. filed a motion to dismiss on the grounds that the circuit court's juvenile division had the exclusive statutory authority to adjudicate the charges pursuant to legislation enacted in 2018. The circuit court agreed and sustained the motion. The Supreme Court reversed, holding (1) the law as it existed at the time R.J.G. was alleged to have committed the offenses governed which division had the authority to adjudicate the offenses; and (2) the juvenile division did not have the statutory to adjudicate the offenses in this case, and therefore, the circuit court erred in dismissing the state's prosecution in the court of general jurisdiction. View "State v. R.J.G." on Justia Law

The Supreme Court made permanent a preliminary writ of mandamus previously issued by this Court directing the circuit court to vacate its order excluding a digital recording from use at trial for various charges relating to the death of Rebecca Ruud's minor daughter, holding that the circuit court erred.A grand jury returned an indictment against Ruud and her then-husband charging them with first-degree murder, felony abuse or neglect of a child resulting in death, and other crimes. The digital recording at issue was between Ruud and her lawyer's staff and yielded incriminating evidence. The circuit court excluded the digital recording from being admitted at trial, concluding that the attorney-client privilege protected the content of the digital recording. The Supreme Court granted the State mandamus relief, holding that the circuit court abused its discretion in finding that the recording was privileged. View "State ex rel. Garrabrant v. Honorable Holden" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree assault of a law enforcement officer, armed criminal action, and unlawful possession of a firearm by a felon, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued that the circuit court erred in overruling with prejudice his motion to dismiss the first-degree assault and armed criminal action counts and retrying him after a mistrial. Defendant's only specific argument was that the circuit court violated the time limitations for his retrial. The Supreme Court affirmed, holding that the circuit court properly followed the procedure approved in State v. Berry, 298 S.W.2d 429 (Mo. 1957), and therefore, Defendant's retrial did not violate Mo. Const. art. I, 19. View "State v. Shegog" on Justia Law

The Supreme Court reversed Defendant's conviction for second-degree felony murder and armed criminal action, holding that the circuit court's evidentiary rulings infringed on Defendant's constitutional right to present a complete defense, as guaranteed by the Sixth and Fourteenth Amendments.Defendant's convictions arose from an alleged robbery during which Defendant shot and killed Mathew Haylock. During trial, Defendant attempted to present evidence that he shot Haylock in self-defense after Haylock attempted to rob him. Each time Defendant raise the issue of presenting his own version of events the circuit court denied him the right to provide such evidence. The Supreme Court reversed and remanded the case, holding that by prohibiting Defendant from presenting evidence about the ultimate issue int his case, the circuit court prevented Defendant from presenting a complete defense, in violation of his constitutional rights. View "Missouri v. Gates" on Justia Law