Justia Missouri Supreme Court Opinion Summaries

The Supreme Court affirmed in part and reversed in part the judgment of the circuit court dismissing Petitioner's petition for declaratory judgment for failure to state a claim upon which relief can be granted, holding that the circuit court improperly dismissed Petitioner's claim with prejudice.In his petition, Petitioner sought a declaration that his federal supplemental security income was exempt under federal law from paying the required monthly intervention fees to the Missouri Department of Corrections, Division of Probation and Parole, as a condition of his supervised probation. The circuit court dismissed the petition with prejudice. The Supreme Court reversed in part, holding (1) Petitioner's request for declaratory relief was not ripe for adjudication; but (2) because Petitioner may be able to state a claim ripe for adjudication in the future, the circuit court improperly dismissed the claim with prejudice. View "Graves v. Missouri Department of Corrections" on Justia Law

The Supreme Court affirmed the order of the circuit court sustaining Defendant's motion to suppress a cell phone and electronic data stored on that cell phone, holding that the circuit court did not err in sustaining the motion to suppress.The circuit court concluded that the search warrant failed to describe with sufficient particularity the thing to be seized and was so facially deficient that the executing officers could not reasonably have presumed it to be valid. The Supreme Court affirmed, holding (1) the seizure of a cell phone at the sheriff's office was outside the scope of the warrant, so the evidence was not validly seized; and (2) the officer conducting the search did not have a good faith basis when he executed the search warrant at the sheriff's office, contrary to the clear directions of the search warrant to search a cell phone located at a particular address. View "State v. Bales" on Justia Law

The Supreme Court denied Defendant's petition for a writ of habeas corpus, holding that Defendant was eligible for the death penalty because he failed to prove that he was intellectually disabled, and Defendant was not entitled to relief on any of his remaining claims.Defendant was found guilty of three counts of first-degree murder and sentenced to three death sentences. After the Supreme Court issued an order setting Defendant's execution date Defendant filed this petition for writ of habeas corpus, raising three allegations. The Supreme Court affirmed, holding (1) Defendant was not intellectually disabled and was therefore eligible for the death penalty; (2) the jury instructions on intellectual disability did not violate Defendant's constitutional rights; and (3) Defendant's method of execution claim failed. View "State ex rel. Johnson v. Blair" on Justia Law

The Supreme Court affirmed the judgment of the motion court overruling Appellant's Rule 24.035 amended motion seeking to set aside his guilty plea and vacate his judgment and sentence, holding that the motion court's findings of fact and conclusions of law were not clearly erroneous.Appellant pleaded guilty to first-degree involuntary manslaughter and armed criminal action and was sentenced to two consecutive terms of fifteen and twenty-five years' imprisonment. Appellant later filed a pro se Rule 24.035 to vacate, set aside, or correct the judgment and sentence. The motion court granted the motion, set aside Appellant's guilty plea, and reinstated his original charges. Thereafter, Appellant pled guilty to second-degree murder and armed criminal action and was sentenced to concurrent terms of life and thirty years' imprisonment. Appellant then filed a second Rule 24.035 motion. The motion court overruled the motion. The Supreme Court affirmed, holding that the motion court did not err. View "Staten v. State" on Justia Law

The Supreme Court reversed the judgment of the postconviction relief court overruling Appellant's Rule 24.035 motion for postconviction relief, holding that the mistaken belief held by Defendant regarding his sentencing, which arose from his plea counsel's direct assurance, resulted in his plea of guilty.After Defendant pleaded guilty to driving while intoxicated plea counsel advised him he would be eligible for long-term treatment under Mo. Rev. Stat. 217.362. The circuit court sentenced Defendant pursuant to that provision, but after sentencing, Defendant discovered he was statutorily ineligible for placement in the program. Defendant filed a motion to vacate, set aside or correct his judgment or sentence, arguing that his guilty plea was involuntary unknowing, and unintelligent. The postconviction relief court overruled the motion. The Supreme Court reversed, holding that prejudice existed and, therefore, the judgment overruling Defendant's motion was clearly erroneous. View "Hefley v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court overruling Defendant's Rule 29.15 motion for postconviction relief, holding that the circuit court's findings of fact and conclusions of law were not clearly erroneous.Defendant was convicted of two counts of first-degree murder, five counts of armed criminal action, and one count each of first-degree burglary, forcible rape, and forcible sodomy. Defendant was sentenced to death for each murder count. In his postconviction motion, Defendant argue that the State committed multiple Brady violations and that trial counsel provided ineffective assistance. The Supreme Court affirmed, holding that the circuit court's findings of fact and conclusions of law were not clearly erroneous. View "Driskill v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court finding Defendant guilty of residing within 1,000 feet of George Washington Carver Middle School, holding that the circuit court did not err in concluding that Defendant was within 1,000 feet of the Carver Middle School property line.On appeal, Defendant argued that the circuit court erred in concluding that the word "school" as used in Mo. Rev. Stat. 566.147, includes the Carver Middle School building as well as the adjoining school property. The Supreme Court affirmed, holding that there was sufficient evidence supporting Defendant's conviction for residing within 1,000 feet of the Carver Middle School property line. View "State v. McCord" on Justia Law

The Supreme Court reversed Defendant's conviction for the class E felony of loitering within 500 feet of a public park, in violation of Mo. Rev. Stat. 566.150, holding that there was insufficient evidence to support the conviction.On appeal, Defendant argued (1) the evidence was insufficient to support the conviction because it failed to show that he was knowingly within 500 feet of a public park or that he was loitering, and (2) section 556.150 is constitutionally invalid because it is vague and overbroad. The Supreme Court agreed with Defendant's first argument, holding that the State failed to introduce evidence from which a fact-finder reasonably could conclude that Defendant was within 500 feet of a public park. View "State v. Lehman" on Justia Law

The Supreme Court dismissed the appeal of the dismissal of a motion for a new trial filed decades after a criminal conviction became final, holding that Appellant was dismissing an order dismissing a motion the circuit court had no authority to sustain.In 1995, Appellant was convicted of murder. In 2019, City of St. Louis Circuit Attorney Kimberly Gardner filed a motion for new trial claiming that there was newly discovered evidence showing Appellant's innocence. The court then concluded that it lacked authority to entertain the motion because the State was not permitted to file the motion and because it was untimely. The Supreme Court affirmed, holding that there was no statutory authority for the right to appeal in this case. View "State v. Johnson" on Justia Law

The Supreme Court affirmed the judgment of the circuit court against Jessica Hicklin in a declaratory judgment action against Eric Schmitt, Missouri's attorney general and other State parties, holding that Hicklin's claims were without merit.Hicklin asserted in her complaint that her 1997 life-without-parole sentence for first-degree murder was invalid following the United States Supreme Court's decisions in Miller v. Alabama, 567 U.S. 460 (2012), and Montgomery v. Louisiana, 136 S. Ct. 718 (2016). The Supreme Court disagreed, holding (1) challenges to the constitutional validity of Missouri statutes are properly brought in a declaratory judgment action; (2) Missouri's General Assembly can accept the Supreme Court's invitation to remedy Miller-affected sentences by supplying parole eligibility; and (3) the Parole Board's authority does not violate the separation of powers. View "Hicklin v. Schmitt" on Justia Law