Justia Criminal Law Opinion Summaries

Amanda Mire was charged with driving while intoxicated. She filed two motions in the Circuit Court of Greene County: one to suppress statements she made after emergency medical personnel involuntarily administered a tranquilizing drug, and another to suppress the results of a blood test taken when she was unable to knowingly consent. After a hearing, the circuit court orally ruled in favor of Mire on both motions, finding that her statements and the blood test results should be suppressed due to her inability to knowingly and voluntarily consent while under the influence of the drug.On February 26, 2024, the circuit court entered a docket entry reflecting its ruling, which unequivocally stated that the statements made after administration of the drug and the consent to the blood draw were suppressed. The court scheduled the next setting for the case and invited Mire’s counsel to provide a written order consistent with the oral pronouncement. On March 11, the court entered a formal “judgment and order” that repeated the substance of the February 26 docket entry. The state filed its notice of appeal on March 11, identifying the March 11 order as the one being appealed.The Supreme Court of Missouri reviewed the case and determined that, under section 547.200.4, the state was required to file its notice of appeal within five days of the entry of the order suppressing evidence. The Court held that the February 26 docket entry constituted the operative order with the substantive effect of suppressing the evidence. Because the state’s notice of appeal was filed more than five days after the February 26 order, the Supreme Court of Missouri dismissed the appeal as untimely. View "State of Missouri vs. Mire" on Justia Law

The case concerns a defendant who, in July 2019, orchestrated a plan to lure a man he believed had wronged him to a house in Springfield, Missouri. The defendant rented a U-Haul van, enlisted two friends, and communicated his intent to harm the victim through text messages and conversations. On the night in question, he picked up the victim, brought him to the designated house, and later drove away with the victim, who was bound and injured. The defendant’s subsequent actions included searching online for ways to dispose of a body, coercing others to help clean the van, and attempting to destroy evidence. The victim was never seen again, and his body was not found, but his blood and personal items were recovered from the van and from a bag the defendant tried to have disposed of.After these events, the Circuit Court of Greene County tried the defendant on charges of first-degree murder and first-degree kidnapping. The jury found him guilty on both counts. At sentencing, the court orally pronounced consecutive life sentences: life without parole for murder and life with the possibility of parole for kidnapping. However, the written judgment mistakenly recorded the sentences as 999 days for each count. The defendant appealed, arguing insufficient evidence for conviction and a material discrepancy between the oral and written sentences.The Supreme Court of Missouri reviewed the case. It held that the evidence was sufficient for a reasonable jury to find the defendant guilty of both first-degree murder and first-degree kidnapping, rejecting the defendant’s arguments regarding the corpus delicti doctrine and the statutory requirements for kidnapping. The court also clarified the correct legal standard for “substantial period” in kidnapping cases. The court affirmed the convictions but remanded the case solely to correct the written judgment to match the oral pronouncement of sentences. View "State v. Winter" on Justia Law

Christopher Scott was charged with first-degree robbery, armed criminal action, and unlawful use of a weapon. After a jury trial, he was found guilty on all counts and sentenced in November 2020. The Missouri Court of Appeals affirmed his conviction, and the mandate was issued on January 19, 2022. Scott then filed a pro se Rule 29.15 motion for postconviction relief on April 11, 2022, raising three claims. A public defender entered an appearance on his behalf but did not request an extension to file an amended motion. The public defender filed an amended motion on August 4, 2022, raising six claims, including the original three. The motion court denied relief on all claims after an evidentiary hearing.The Missouri Court of Appeals reviewed the case and transferred it to the Supreme Court of Missouri. The Supreme Court of Missouri noted that the amended motion was filed late and without an extension request. The court emphasized that the deadlines in Rule 29.15 are mandatory and that the abandonment doctrine, which can excuse untimely filings, applies only to appointed counsel, not to unappointed counsel. Since the public defender was not officially appointed, the abandonment doctrine did not apply.The Supreme Court of Missouri held that the motion court should not have considered the untimely claims in the amended motion. As Scott did not challenge the denial of his original pro se claims, the court affirmed the motion court's judgment denying postconviction relief on those claims. The court concluded that the amended motion's additional claims were not properly before the motion court due to the untimely filing. Therefore, the judgment of the motion court was affirmed. View "Scott v. State" on Justia Law

Cedric Mack was charged with driving while intoxicated as a persistent offender. After a jury trial, he was found guilty and sentenced by the circuit court. Mack appealed, and the court of appeals affirmed his conviction. Subsequently, Mack filed a pro se Rule 29.15 motion for postconviction relief, which included a request for a public defender. A public defender later entered an appearance and filed an amended motion. The motion court overruled the amended motion after an evidentiary hearing. Mack appealed, and the court of appeals remanded the case for findings of fact, conclusions of law, and an abandonment inquiry. On remand, the motion court found the public defender had abandoned Mack, considered the amended motion on the merits, and denied relief again. Mack appealed.The Supreme Court of Missouri reviewed the case. The court noted that Mack's amended motion was not timely filed under the applicable version of Rule 29.15(g). The court also found that the public defender's entry of appearance without being appointed meant the abandonment doctrine did not apply. Consequently, the only issue was whether Mack's single pro se claim needed to be resolved again. The court determined it did not, as the claim had already been raised and decided in Mack's direct appeal.The Supreme Court of Missouri held that Mack's pro se Rule 29.15 motion was the only timely filed motion and contained a single claim identical to one previously rejected on direct appeal. Therefore, the judgment of the motion court denying postconviction relief was affirmed. View "Mack v. State" on Justia Law

In 2020, C.S. pleaded guilty to two charges in the Lafayette County circuit court: possession of a controlled substance for possessing more than 35 grams of marijuana, and unlawful use of a weapon for possessing a firearm while knowingly in possession of a controlled substance. He was sentenced to seven years and four years of imprisonment, respectively, but the execution of his sentence was suspended. After his probation was revoked in 2021, C.S. was incarcerated. Following the approval of Amendment 3 in 2022, which allows expungement for certain marijuana offenses, C.S. filed a petition to expunge both convictions.The Lafayette County circuit court expunged C.S.'s conviction for possession of a controlled substance but denied the petition to expunge the conviction for unlawful use of a weapon. The court reasoned that the unlawful use of a weapon is a "weapons offense" and not eligible for expungement under the Missouri Constitution's article XIV, § 2.10(7)(a)c.The Supreme Court of Missouri reviewed the case and affirmed the circuit court's judgment. The court held that the offense of unlawful use of a weapon for possessing a firearm while knowingly in possession of a controlled substance is not a "marijuana offense" within the meaning of article XIV, § 2 of the Missouri Constitution. The court concluded that the primary purpose of the statute criminalizing unlawful use of a weapon is to prevent conduct that endangers others, and therefore, it is not eligible for expungement under the constitutional provision. View "C.S. v. Missouri State Highway Patrol Criminal Justice Information Service" on Justia Law

In August 2018, Jessie Nelson was seen at the scene of a shooting that resulted in one death and one permanent injury. He was charged with first-degree murder, first-degree assault, and two counts of armed criminal action. After a jury trial, Nelson was found guilty on all counts and sentenced in January 2020. The court of appeals affirmed the conviction in December 2021. Nelson filed a pro se Rule 29.15 motion in March 2022, and a public defender was appointed the same day. The public defender filed an amended motion in July 2022, which was overruled after an evidentiary hearing in August 2023. Nelson appealed.Cameron Woods was charged with unlawful use of a weapon and entered an open plea of guilt in March 2021. He was sentenced to 15 years’ imprisonment in May 2021. Woods did not appeal but filed a pro se motion under Rule 24.035 in October 2021. A public defender was appointed in November 2021, and an amended motion was filed in April 2022. The motion was overruled after an evidentiary hearing in November 2023. Woods appealed.The Supreme Court of Missouri reviewed the cases and found that both Nelson and Woods were abandoned by their appointed counsel due to untimely filing of amended motions. The court determined that remand for an abandonment inquiry was unnecessary as the records clearly showed abandonment. The court affirmed the motion courts' judgments, finding no clear error in their rulings on the merits after conducting evidentiary hearings. Nelson's claims of ineffective assistance of counsel were denied, and Woods' claim regarding the failure to call an expert witness at sentencing was also denied. The judgments denying postconviction relief were affirmed. View "Nelson v. State" on Justia Law

Robert J. Branson was charged with six sex crimes, including three unclassified felonies, for raping and sodomizing a child. On the day of the trial, Branson negotiated an Alford plea to one count of first-degree child molestation (class A felony) and two counts of second-degree statutory rape. The State amended the charges accordingly. During the plea hearing, Branson acknowledged he was charged with a class A felony and faced a potential life sentence. The circuit court accepted his plea and sentenced him to life imprisonment for the class A felony and consecutive seven-year terms for the two counts of second-degree statutory rape.Branson filed a Rule 24.035 motion for postconviction relief but did not allege a factual defect in his guilty plea or that his sentence exceeded the statutory maximum. The circuit court overruled the motion. On appeal, Branson claimed for the first time that the State failed to allege the necessary facts for a class A felony. The court of appeals affirmed the judgment, holding that Branson waived this argument by not raising it in his Rule 24.035 motion.Branson then filed a petition for a writ of habeas corpus, alleging his sentence was excessive because the factual basis for his guilty plea only supported a class B felony. The circuit court denied the petition, but the court of appeals granted it. The Supreme Court of Missouri reviewed the case and denied habeas relief, holding that Branson waived his sentencing claim by not raising it in his Rule 24.035 motion. The court found no jurisdictional defect, cause and prejudice, or manifest injustice warranting habeas review of the procedurally defaulted claim. The court overruled previous cases that allowed habeas review for sentencing errors as jurisdictional defects. View "Branson v. Shewmaker" on Justia Law

David Thompson was convicted of fourth-degree domestic assault and violating an order of protection. He appealed, arguing that the circuit court made three errors: (1) denying his motion to dismiss due to lack of counsel at his preliminary hearing, (2) rejecting his proposed lesser-included offense instruction for fourth-degree domestic assault, and (3) submitting a corrective instruction after the jury announced its verdicts.Thompson was charged with felony domestic assault for hitting his ex-boyfriend with a vehicle, violating a protective order. At his preliminary hearing, Thompson was unrepresented, and the associate circuit division found probable cause to proceed to trial. Thompson later moved to dismiss, claiming his right to counsel was violated, but the circuit court denied the motion. At trial, the jury was instructed on third-degree domestic assault and a lesser-included offense of fourth-degree domestic assault. The jury found Thompson not guilty of third-degree domestic assault but guilty of the lesser charge and violating the protective order. After the verdicts, the court discovered inconsistent verdicts for Count I and issued a corrective instruction, leading the jury to clarify its guilty verdict for fourth-degree domestic assault.The Supreme Court of Missouri reviewed the case. It held that Thompson's right to counsel was not violated because he had ample opportunity to retain counsel but failed to do so. The court also found no error in the circuit court's rejection of Thompson's proposed instruction, as the given instruction was appropriate and there was no rational basis for the jury to acquit him of the charged offense while convicting him of the lesser-included offense. Lastly, the court ruled that the corrective instruction was proper and did not prejudice Thompson, as the jury had not been discharged and the court acted within its authority to resolve the inconsistency.The Supreme Court of Missouri affirmed the circuit court's judgment. View "State v. Thompson" on Justia Law

In July 1991, Christopher Dunn was convicted of first-degree murder, two counts of first-degree assault, and three counts of armed criminal action. He was sentenced to life in prison without parole for the murder, 30 years for each assault, and 10 years for each armed criminal action, all to be served consecutively. In February 2024, the St. Louis circuit attorney filed a motion to vacate Dunn’s convictions, citing new evidence of actual innocence. The circuit court held an evidentiary hearing and found clear and convincing evidence of Dunn’s innocence, vacating his convictions and ordering his release. The attorney general opposed this and filed a notice of appeal.The circuit court ordered Dunn’s release, but the attorney general sought a writ of prohibition or mandamus from the Supreme Court of Missouri to prevent the release. The Supreme Court issued a temporary stay and later a permanent writ prohibiting Dunn’s release without the state’s intent to retry him. The circuit court amended its judgment, and Dunn was released after the circuit attorney filed a memorandum of nolle prosequi. The attorney general appealed, but the circuit attorney moved to dismiss, arguing the state had no right to appeal under section 547.031.The Supreme Court of Missouri reviewed whether the state could appeal the judgment vacating Dunn’s convictions. The court held that the state is an aggrieved party with a statutory right to appeal under section 512.020(5). The court found that section 547.031 did not limit the state’s right to appeal and that the state’s interest in the finality of its convictions made it an aggrieved party. The court retransferred the case to the court of appeals to overrule the circuit attorney’s motion to dismiss and proceed with the state’s appeal on the merits. View "In re: Circuit Attorney, 22nd Judicial Circuit ex rel. Dunn" on Justia Law

Anthony Tate was convicted of first-degree murder, two counts of first-degree assault, unlawful use of a weapon, unlawful possession of a weapon, and four counts of armed criminal action. The charges stemmed from an incident where Tate fired 15 shots into a vehicle, killing one passenger and injuring two others. The injured passengers, A.H. and M.E., sustained gunshot wounds that required medical treatment and resulted in protracted impairment. Tate was identified through video surveillance and social media posts, and the gun used in the shooting was found in his possession.The Circuit Court of St. Louis County found Tate guilty on all counts. Tate appealed, challenging the sufficiency of the evidence for the first-degree assault convictions, the failure of the circuit court to issue a corrective instruction regarding the State’s closing argument, and the admission of hearsay testimony from a detective. The Missouri Court of Appeals reviewed the case and upheld the circuit court’s judgment.The Supreme Court of Missouri affirmed the lower court’s decision. The court held that there was sufficient evidence to support the first-degree assault convictions, as the injuries sustained by A.H. and M.E. constituted serious physical injury with protracted impairment. The court also found no plain error in the circuit court’s failure to issue a corrective instruction regarding the State’s closing argument or in admitting the detective’s testimony. The court concluded that the evidence presented at trial was sufficient for a reasonable juror to find Tate guilty beyond a reasonable doubt. View "State v. Tate" on Justia Law