Justia Criminal Law Opinion Summaries

The State charged Defendant with unlawful possession of a firearm in violation of Mo. Rev. Stat. 571.070.1(1). Under a 2008 amendment to the statute, a defendant commits unlawful possession of a firearm if he has been convicted of any other felony. The third count of the indictment alleged that Defendant had been convicted of felony possession of a controlled substance in September 2002. Defendant filed a motion to dismiss the third count of the indictment, asserting (1) when he was convicted of possession of a controlled substance, that conviction did not prohibit him from owning a firearm under the version of section 571.070 in effect at that time; and (2) the 2008 amendment of the statute, as applied to him and his 2002 conviction, violated the Missouri Constitution's ban on retrospective laws by imposing a "new duty or obligation" on him. The circuit court sustained Defendant's motion. The Supreme Court reversed, holding (1) the Constitution's ban on the passage of any law retrospective in its operation does not apply to criminal laws; and (2) because section 571.070.1(1) is a criminal law, the circuit court erred in dismissing the charge against Defendant on the ground that the statute was unconstitutionally retrospective as applied to him. View "State v. Honeycutt" on Justia Law

After a jury trial, Appellant was convicted of first-degree statutory sodomy. Appellant's conviction was confirmed on appeal. Appellant filed a pro se motion for post-conviction relief, alleging that he received ineffective assistance of counsel and that the prosecutor committed misconduct. The motion court overruled Appellant's post-conviction relief motion without an evidentiary hearing. The Supreme Court affirmed, holding (1) Appellant's motion for post-conviction relief failed to allege facts not refuted conclusively by the record to support his claims for ineffective assistance of counsel; and (2) the motion court did not clearly err in finding that the prosecutor's conduct was appropriate. View "McIntosh v. State" on Justia Law

After a jury trial, Appellant was convicted of burglary in the second degree and stealing. The convictions were affirmed on direct appeal. Appellant subsequently filed a motion for post-conviction relief alleging that trial counsel was ineffective for failing to request a trespassing instruction as a lesser-included offense of burglary. The motion court overruled Appellant's claim without holding an evidentiary hearing. The Supreme Court reversed, holding that the motion court erred in failing to holding evidentiary hearing on Appellant's claims, as Appellant alleged facts, not clearly refuted by the record, showing he was prejudiced by counsel's failure to submit a lesser-included offense instruction. Remanded. View "McNeal v. State" on Justia Law

In 2001, Respondent pleaded guilty to the class B felony of possession of a controlled substance with intent to distribute. In 2011, Respondent was indicted for knowingly and unlawfully possessing a .38 caliber revolver in violation of Mo. Rev. Stat. 571.070, which provides that a person commits unlawful possession of a firearm if he knowingly has a firearm in his possession and has been convicted of a felony. Respondent moved to quash or dismiss the indictment, arguing that section 571.070 violated the Missouri Constitution as applied to him because it was an ex post facto law. The circuit court entered judgment in favor of Respondent. The Supreme Court reversed, holding that section 471.070 was not an ex post facto law because it did not apply to conduct completed before its enactment. View "State v. Harris" on Justia Law

In 1994, Appellant pleaded guilty to sodomy. Congress subsequently passed the federal sex offender registration act (SORNA), which required individuals such as Appellant to register as sex offenders. Before SORNA was enacted, Appellant completed his involvement in the criminal justice system. Appellant filed a petition challenging SORNA's constitutional validity as applied to him. The circuit court entered summary judgment against Appellant. The Supreme Court affirmed, holding (1) SORNA does not violate the nondelegation doctrine; (2) the registration requirement does not violate Appellant's right to substantive due process nor the prohibition in the U.S. Constitution against ex post facto criminal laws; and (3) SORNA complies with principles of federalism. View "Roe v. Replogle" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. After the jury was unable to agree on punishment, the trial court conducted an independent review of the facts pursuant to Mo. Rev. Stat. 565.030.4 and imposed the death sentence. The Supreme Court affirmed the conviction and sentence, holding (1) any errors in the preparation of the trial transcript did not impede adequate appellate review and were not prejudicial; (2) the trial court did not err in its evidentiary rulings or in its instructions to the jury; (3) section 565.030.4 is not unconstitutional; (4) the trial court did not commit plain error in failing to hold a hearing regarding alleged the improper influence of a certain juror during jury deliberations; and (5) the death sentence in this case was proportional to the strength of the evidence. View "State v. Shockley" on Justia Law

After a jury trial, Defendant was found guilty of twenty-six counts of first-degree murder, burglary, and related crimes for actions he took during a robbery and home invasion when he was sixteen years old. The trial court sentenced Defendant to life in prison with no possibility of parole for first-degree murder. The circuit court dismissed four counts on which the jury had found Defendant guilty, finding it had no jurisdiction over the charges because they were outside the scope of the juvenile court's certification. The Supreme Court held, inter alia, (1) the trial court erred in dismissing the four counts related to one of the victims of Defendant's crimes because she was not named in Defendant's juvenile petition; (2) the evidence at trial was sufficient to prove first-degree murder; and (3) Defendant's sentence of life without parole for first-degree murder violated the Eighth Amendment because it was imposed with no individualized consideration of the myriad of factors discussed in Miller v. Alabama. Remanded for resentencing. View "State v. Nathan" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder, first-degree robbery, and two counts of armed criminal action for shooting a killing a victim during the second of two robberies he committed when he was seventeen years old. The trial court sentenced Defendant to life in prison without the possibility of parole for murder. The Supreme Court affirmed, holding (1) the trial court did not reversibly err in playing Defendant's videotaped interrogation at trial; and (2) Defendant's sentence of life without parole violated the Eighth Amendment because it was imposed without any opportunity for the sentencing court to consider whether this punishment was appropriate in light of Defendant's age, maturity, and other factors discussed in Miller v. Alabama. Remanded. View "State v. Hart" on Justia Law

After a jury trial, Defendant was convicted of involuntary manslaughter in the first degree and armed criminal action. Defendant subsequently filed a petition for a writ of habeas corpus, claiming that the trial court's practice of permitting qualified jurors to opt out of jury service by agreeing to perform community service constituted a fundamental and systemic failure to comply with the statutory jury selection requirements. The circuit court and court of appeals denied the motion. Defendant then filed his writ petition with the Supreme Court. The Supreme Court denied the petition, holding that allowing five prospective jurors to opt out of service during Defendant's trial did not constitute a "substantial failure" to comply with the jury selection statutes or undermine the confidence in the verdict. View "State ex rel. Sitton v. Norman" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to death. Defendant subsequently filed a motion for post-conviction relief. The motion court denied the motion after an evidentiary hearing on five of Defendant's fourteen allegations of error. The supreme Court affirmed, holding, among other things, that the motion court did not clearly err in (1) denying Defendant's claim that his trial counsel were ineffective for failing to investigate and present a diminished capacity defense; (2) failing to find the State committed a Brady violation; and (3) failing to find Defendant's trial counsel were ineffective for failing to object to the admission of a reenactment video without an evidentiary hearing. View "Johnson v. State" on Justia Law