Justia Criminal Law Opinion Summaries

In 1983, Respondent pleaded guilty to one count of first-degree sexual assault. In 1995, Missouri's Sex Offender Registration Act (SORA) became effective, requiring Respondent to register as a sex offender. In 2010, Respondent filed a declaratory judgment action asserting that SORA violates Mo. Const. art I, 13 and that he was not required to register pursuant to the federal Sexual Offenders Registration and Notification Act (SORNA). The trial court (1) entered a declaratory judgment finding that, as applied to Respondent, SORA violated the bar against the enactment of retrospective state laws set forth in article I, section 13; and (2) declined to address the applicability of SORNA, therefore declining to order Defendants to remove Respondent's name from the registry and to destroy all registration records. The Supreme Court (1) reversed the judgment to the extent it held that the trial court was without authority to address the applicability of SORNA and that the SORA registration requirements violated article I, section 13 as applied to Respondent; and (2) affirmed the judgment to the extent that it did not order Defendants to destroy the registration records. View "Doe v. Toelke" on Justia Law

Defendant appealed the circuit court's judgment convicting him of five counts of possession of child pornography. Defendant asserted three points on appeal. The Supreme Court affirmed the judgment, holding (1) the trial court did not err in overruling Defendant's motion to suppress an affidavit offered in support of the search warrant used to seize the evidence because the affidavit established probable cause; (2) the entry of five separate convictions did not constitute double jeopardy or violate Defendant's rights to due process and trial by jury; and (3) the trial court properly admitted evidence of the content of resumes found on Defendant's computer. View "State v. Roggenbuck" on Justia Law

Appellant was convicted by a jury of first-degree murder, kidnapping, attempted forcible rape, and armed criminal action. The trial court sentenced Appellant to death and three life sentences to be served consecutively. After the Supreme Court affirmed his convictions, Appellant filed a motion for post-conviction relief, alleging several instances in which his trial counsel rendered ineffective assistance. The motion was overruled after an evidentiary hearing. The Supreme Court affirmed the judgment denying post-conviction relief, holding that the motion court did not clearly err in denying Appellant post-conviction relief, as Appellant's assertions of ineffective assistance of counsel were without merit. View "Johnson v. State" on Justia Law

The State appealed two judgments declaring Mo. Rev. Stat. 556.036 unconstitutional and dismissing, with prejudice, the criminal charges against Grant Mixon and Jeffrey Anderson. The judgments of the circuit court declared section 556.036 unconstitutional for conflicting with Mo. Const. art. I, 17, which prohibits felony prosecutions "otherwise than by indictment or information," because the circuit court determined the statute allowed for prosecution of a felony by complaint. The Supreme Court reversed, holding that Mixon and Anderson failed to demonstrate that section 556.036.5 "clearly and undoubtedly" violated Mo. Const. art. I, 17. Remanded. View "State v. Mixon" on Justia Law

A jury found Appellant guilty of four counts of first-degree murder and armed criminal action for the shooting deaths of his girlfriend and her three children. Appellant was sentenced to death for his crimes. Appellant subsequently filed a motion for post-conviction relief, alleging ineffective assistance of counsel. After an evidentiary hearing regarding some of Appellant's claims, the motion court overruled his motion. The Supreme Court affirmed, holding that Appellant failed to make a sufficient showing to support Strickland v. Washington's prejudice prong because of the overwhelming evidence presented that established his guilt, and therefore, the motion court did not err in overruling the motion. View "Taylor v. State" on Justia Law

The State issued a warrant for Defendant's arrest after it was discovered that he was secretly videotaping clients while they undressed at his massage therapy business. Defendant was arrested and sought release on bail. Pursuant to Mo. R. Crim. P. 33.01, the circuit court set a $75,000 cash-only bond. Defendant sought relief of the court's order, arguing that the setting of a cash-only bond violates the requirement of Mo. Const. art. I, 20 that the bail shall be permitted by "sufficient sureties." After considering the purposes and the history of bail as well as the numerous understandings of the word "sufficient surety," the Supreme Court held that the trial court did not err in exercising its discretion to require a cash-only bond, as the imposition of a cash-only bail does not violate the Missouri Constitution. View "State v. Jackson" on Justia Law

Appellant was found guilty by a jury of robbery in the first degree, armed criminal action, and unlawful use of a weapon. The appellate court affirmed. Appellant filed a Mo. R. Crim. P. 29.15 motion, alleging his trial counsel was ineffective for not calling a witness to testify and because his appellate counsel was ineffective in failing to raise a meritorious issue on appeal. The circuit court overruled Appellant's motion without a hearing. The Supreme Court affirmed because (1) the testimony of the witness did not negate an element of the crime and would not produce a viable defense, and (2) Williams could not demonstrate a reasonable probability that the outcome wold have been different had his appellate counsel raised the sufficiency of the evidence claim on appeal. View "Williams v. State" on Justia Law

Appellant was found guilty by a jury of the unlawful use of a weapon pursuant to Mo. Rev. Stat. 571.030.1. Appellant appealed, arguing that the circuit court erred in overruling his motion for a judgment of acquittal because there was insufficient evidence presented at trial that the weapon was concealed and that the weapon was a functional lethal weapon. The Supreme Court granted transfer after opinion by the court of appeals. The Court then affirmed the circuit court's judgment, holding (1) the evidence was sufficient to find Appellant concealed the firearm on or about his person; and (2) section 571.030.1 does not require the State to introduce evidence of the firearm's "functionality" in order to gain a conviction for the unlawful use of a weapon. View "State v. Wright" on Justia Law

Defendant was convicted and sentenced to twelve years without probation or parole for the class A felony of trafficking drugs in the first degree. On appeal, Defendant claimed, inter alia, that the trial court erred in overruling his objection to a verdict-directing instruction because it did not require the jury to find Defendant knew of the substance's content and character. The Supreme Court reversed, holding (1) the trial court's failure to instruct the jury to find that Defendant knew the content or character of the drugs relieved the State of its burden of proving each element of the offense beyond a reasonable doubt; and (2) this failure was plain error and required the reversal of Defendant's conviction and sentence. Remanded for a new trial. View "State v. Stover" on Justia Law

The Missouri Public Defender Commission petitioned the Supreme Court for a writ of prohibition ordering the trial court to withdraw its appointment of the public defender's office to represent Defendant, alleging that the appointment violated 18 C.S.R. 10-4.010 (the rule). The rule, promulgated by the Commission, adopts a "caseload protocol" that permits a district defender office to decline additional appointments when it has been certified as being on limited availability after exceeding its caseload capacity for at least three consecutive calendar months. The trial court did not refuse to apply the rule, but rather, the trial court said it believed it had no choice but to appoint a public defender because to do otherwise would have violated Defendant's Sixth Amendment right to counsel, as the court could identify no other realistic mechanism by which to provide other counsel. The Supreme Court ordered the trial court to vacate its order, holding that the court erred by (1) determining that the Sixth Amendment requires appointment of counsel without regard to whether counsel would be able to offer competent representation; (2) failing to apply the rule; and (3) holding that the rule provides no realistic alternative mechanisms for handling the issue of excessive appointments.