Justia Missouri Supreme Court Opinion Summaries

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 Appellant argued on appeal that he was wrongly convicted under a section of state law that had been repealed in 1983, and that no other statute replaced it that criminalized the murder for which he was charged.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.

A young woman died from injuries she sustained after falling from a portable rock climbing wall at a minor league baseball game. Her parents sued the team's owner, who had an excess insurance policy with Respondent Great American Assurance Company (Great American). To protect himself from additional liability, the team owner entered into an agreement with the parents that limited collection of any judgment to the limits of both primary and excess insurance policies. The trial court entered judgment against the team owner, finding him liable, and awarded $4 million in damages. The parents then brought an equitable garnishment suit to collect against the primary and excess policies. The primary insurers settled for less than their policy limit. However, the parents entered a release of judgment for the full policy limit. The excess insurer, Great American, disputed its obligation to pay under its policy because the primary insurance limit had not been exhausted. The appellate court agreed with Great American, and denied the parents equitable garnishment. The parents appealed, arguing that the excess insurance policy did not require exhaustion before it was obligated to pay. The Supreme Court reviewed the policy and found it had no provisions requiring exhaustion. The Court reversed the appellate court on the exhaustion issue, and affirmed the lower court's decision on all other matters brought on appeal.