Justia Criminal Law Opinion Summaries

After a jury trial, Defendant was convicted of two counts of sexual misconduct involving a child pursuant to Mo. Rev. Stat. 566.083 and two counts of attempted sexual misconduct involving a child. The convictions arose from incidents in which Defendant knowingly exposed his genitals to young girls from the front door or window of his house. Defendant appealed, arguing (1) section 566.083 is unconstitutionally overbroad because it infringes on activities protected by Fifth and Fourteenth Amendments, (2) the statute is unconstitutional as applied, and (3) insufficient evidence supported his convictions. The Supreme Court affirmed, holding (1) because Defendant failed to show how section 566.083 serves to discourage citizens from engaging in protected speech, Defendant failed to demonstrate that the statute is overbroad; (2) section 566.083 is constitutional as applied to Defendant; and (3) the evidence presented at trial was sufficient for a jury to convict Defendant of the crimes beyond a reasonable doubt. View "State v. Jeffrey" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to life imprisonment. The court of appeals affirmed Defendant's conviction and denied her motion for post-conviction relief. Approximately thirteen years later, Defendant filed a motion to re-open her post-conviction proceedings, claiming that she had been abandoned by her appointed counsel and that her conviction should be vacated to correct a manifest injustice. The motion court denied Defendant relief, finding that Defendant's motion was a prohibited successive motion. The Supreme Court affirmed after directing attorneys in such situations to file a motion for post-conviction relief due to abandonment, holding that the motion court did not clearly err in overruling Defendant's motion, as a motion to "re-open" does not exist in the Court's rules. View "Eastburn v. State" on Justia Law

After a trial, Defendant was convicted of misdemeanor criminal nonsupport. Defendant appealed, contending that the trial court erred in overruling his motion for judgment of acquittal claiming Mo. Rev. Stat. 568.040 violated his due process rights because it forced him to disprove an element of the offense. Specifically, Defendant asserted that section 568.040 was unconstitutional because it makes lack of good cause an element of the crime of criminal support but then shifts the burden of proving good cause to the defendant. The Supreme Court affirmed the conviction, holding (1) the statute makes lack of good cause an element of the offense that the State must prove beyond a reasonable doubt; and (2) sufficient evidence supported the trial judge's conclusion that Defendant's failure to pay the ordered child support was without good cause. View "State v. Holmes" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder and was sentenced to death for one of the murders. The Supreme Court reversed the death sentence and remanded the case for a retrial of the penalty phase. At the retrial, Defendant was again sentenced to death. Defendant subsequently filed a pro se Mo. R. Crim. P. 29.15 motion for post-conviction relief challenging various aspects of his penalty-phase retrial. The judge assigned to hear the Rule 29.15 motion had presided over Defendant's first trial, Defendant's first post-conviction motion hearing, and the penalty-phase retrial. The motion court overruled Defendant's second Rule 29.15 motion. The Supreme Court reversed, holding (1) the judge presiding over Defendant's post-conviction proceedings erred in overruling Defendant's motion to disqualify the judge for cause because a reasonable person could find an appearance of impropriety where the judge's references in the record to extrajudicial information in Defendant's first trial suggested that the judge relied on that information in ruling on Defendant's Rule 29.15 motion; and (2) therefore, recusal was required. Remanded. View "Anderson v. State" on Justia Law

Defendant pleaded guilty to first degree assault and armed criminal action (ACA). Defendant subsequently filed a motion for post-conviction relief pursuant to Mo. R. Crim. P. 24.035, alleging ineffective assistance of counsel. The circuit court dismissed the motion as untimely filed because Defendant filed it within 180 days of his delivery to the department of corrections for his first degree assault sentence, which triggered the period in which he could file a post-conviction relief motion challenging that conviction and sentence. The court of appeals affirmed, holding that the triggering event was Defendant's previous delivery to the department of corrections to serve his ACA sentence imposed in the same judgment. The Supreme Court affirmed, holding (1) the circuit court did not err in dismissing Defendant's motion as to his claim of ineffective assistance of plea counsel because the claim was not timely filed; and (2) Defendant's claim that his counsel at his probation revocation hearing on his assault conviction was ineffective was not cognizable in a Rule 24.035 proceeding. View "Swallow v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree robbery, forcible rape, attempted forcible rape, and forcible sodomy. Defendant appealed, claiming (1) the trial court erred in admitting into evidence his incriminating statements to police because the statements were made involuntarily in reliance on an agreement the state failed to honor, and (2) there was insufficient evidence to support his conviction of two separate counts of first-degree robbery. The Supreme Court (1) vacated Defendant's for first-degree robbery as charged in the second count based on the state's concession Defendant was wrongfully subjected to multiple convictions for taking multiple items of property from the victim in the course of a single incident; and (2) affirmed the judgment in all other respects, holding that the trial court did not err in admitting Defendant's pretrial statements, as the facts clearly supported the trial court's finding that Defendant's statements were voluntary. View "State v. Hicks" on Justia Law

After a jury trial, Plaintiff was found guilty of first-degree murder and armed criminal action. The circuit court sentenced Defendant to death. The Supreme Court affirmed the judgment, holding (1) the trial court did not plainly err in its rulings regarding the jury and jury instructions; (2) the prosecutor did not engage in improper arguments or make improper comments; (3) the trial court did not err in its evidentiary rulings; (4) the trial court did not err in its rulings during the penalty phase; and (5) in this case, the death penalty complied with all statutorily proportionality requirements. View "State v. McFadden" on Justia Law

After a jury trial, Defendant was convicted of two counts of harassment, one under Mo. Rev. Stat. 565.090.1(2) and one under section 565.090.1(5), and one count of possession of marijuana. The harassment charges stemmed from emails Defendant sent to public officials that contained personally offensive language and references to sawed-off shotguns, assassinations, and domestic terrorism. The Supreme Court affirmed in part and reversed in part, holding (1) the content of Defendant's emails did not constitute protected speech, and therefore, section 565.090.1(2) was constitutional as applied to Defendant, and there was sufficient evidence to support his conviction on that count; and (2) the judgment as to the second count of harassment was set aside, as State v. Vaughn invalidated section 565.090.1(5), and manifest injustice would result if the conviction under that statute was not reversed. View "State v. Wooden" on Justia Law

After a jury trial, Defendant was convicted of murder, assault, burglary, and armed criminal action. Defendant subsequently filed a petition for writ of habeas corpus, petitioning the Supreme Court to vacate his convictions and to grant him a new trial because newly discovered evidence showed (1) the State violated Brady v. Maryland by withholding material, favorable evidence, and (2) the lack of disclosure of this Brady material was prejudicial. After a hearing, a special master found that the State had violated Brady in at least two important and material respects and that the State's failure to produce this Brady material was prejudicial. The Supreme Court concluded that substantial evidence supported the master's findings and, accordingly, ordered that Defendant's convictions be vacated and ordered him discharged from the custody of the department of corrections unless the State filed in the circuit court an election to retry him. View "State ex rel. Woodworth v. Denney" on Justia Law

Defendant pleaded guilty to three counts of statutory sodomy in the first degree. Before trial, a third amended information was filed that charged Defendant as a predatory sex offender on Counts I and III. A factual basis of Defendant's guilt and status as a predatory sex offender was established at the plea hearing. Defendant filed a motion for post-conviction relief, alleging (1) his constitutional right to a jury trial was denied when the circuit court overruled his motion challenging the trial court's determination of his classification as a predatory sexual offender under Mo. Rev. Stat. 558.018, and (2) his due process rights were violated when the trial court overruled his motion challenging the hearing classifying him as a predatory sexual offender under Mo. Rev. Stat. 558.021.2 before the commencement of the scheduled jury trial. The motion court overruled Defendant's post-conviction motion without an evidentiary hearing. The Supreme Court affirmed, holding that the motion court did not clearly err in determining Defendant waived his constitutional challenges when he pleaded guilty. View "Garris v. State" on Justia Law