Justia Criminal Law Opinion Summaries

In the early morning, a police officer stopped Chad Thomas for driving with a broken headlight. During the stop, Thomas exhibited unusual behavior, such as rolling down the rear window instead of the front, being unable to find his driver’s license, and acting nervously. The officer conducted a pat-down search, during which Thomas mentioned he might have a "sharp," a term the officer associated with drug use. Thomas's behavior, including blocking the officer's view and lying about having his license, led the officer to call for a canine unit, which eventually alerted to the presence of drugs.The Circuit Court of Saline County overruled Thomas's motion to suppress the evidence found during the search, concluding that the officer had reasonable suspicion to extend the stop based on Thomas's behavior. The court found that the extension of the stop was justified by Thomas's actions and the need to verify his identity and the outstanding warrant. The court admitted the evidence, and the jury found Thomas guilty of possession of a controlled substance and unlawful possession of drug paraphernalia. Thomas was sentenced to 10 years in prison.The Supreme Court of Missouri reviewed the case and affirmed the circuit court’s judgment. The court held that the officer had reasonable suspicion to extend the traffic stop based on the totality of Thomas's behavior, which included nervousness, evasive actions, and inconsistent statements. The court found that the detention and subsequent search were lawful under the Fourth Amendment, as the officer's actions were justified by reasonable suspicion of criminal activity. View "State vs. Thomas" on Justia Law

Richard Emery was convicted of four counts of first-degree murder and sentenced to death for each count. Emery admitted to killing his girlfriend K.K., her mother J.M., and K.K.'s two children, Z.K. and J.K., but argued he did not deliberate before the murders. The jury rejected this argument, finding overwhelming evidence of deliberation. Emery appealed, claiming errors in jury selection, evidence admission, the prosecutor's closing argument, and alleged religious bias by the judge.The Circuit Court of St. Charles County struck a potential juror for cause, admitted body-camera footage and testimony about Emery's shootout with police and attempted carjacking, and allowed victim impact testimony from the officers and a carjacking victim during the penalty phase. Emery's objections to these decisions were overruled. The court found the evidence of deliberation compelling, noting Emery's methodical actions before and after the murders, including his calm demeanor and attempts to escape.The Supreme Court of Missouri reviewed Emery's claims and found no abuse of discretion or plain error. The court held that the body-camera footage and testimony about the shootout and carjacking were relevant to proving deliberation and providing a complete picture of the events. The court also found that the victim impact testimony was permissible under Missouri law. The prosecutor's closing argument did not constitute improper personalization, and the judge's comments about Emery's lack of spirituality were not indicative of religious bias.The court conducted an independent proportionality review and concluded that the death sentences were not imposed under the influence of passion, prejudice, or any other arbitrary factor. The evidence supported the jury's finding of statutory aggravating circumstances, and the sentences were not excessive or disproportionate compared to similar cases. The Supreme Court of Missouri affirmed the judgment of the Circuit Court. View "State v. Emery" on Justia Law

In 1998, the defendant fatally stabbed the victim during a burglary. The victim's belongings were found in the defendant's vehicle, and two witnesses testified that the defendant confessed to the crime. In 2001, a jury convicted the defendant of first-degree murder and other charges, sentencing him to death. Over the next 23 years, the defendant's claims of actual innocence and constitutional errors were repeatedly rejected by state and federal courts.The defendant's direct appeal was denied by the Missouri Supreme Court in 2003, and his post-conviction relief appeal was denied in 2005. The federal district court initially granted habeas relief, but the Eighth Circuit reversed this decision in 2012. The U.S. Supreme Court denied certiorari in 2013. Subsequent habeas petitions and requests for DNA testing were also denied by the Missouri Supreme Court and the U.S. Supreme Court.The Missouri Supreme Court reviewed the case and affirmed the lower court's judgment. The court found no clear and convincing evidence of actual innocence or constitutional error that would undermine confidence in the original judgment. The court noted that recent DNA testing did not support the defendant's claim of innocence and that the evidence showed the killer wore gloves, which aligned with the trial testimony. The court also rejected claims of ineffective assistance of counsel and Batson violations, as these issues had been previously adjudicated and found to be without merit.The Missouri Supreme Court affirmed the circuit court's judgment, denying the motion to vacate or set aside the conviction and sentence. The court held that the defendant failed to demonstrate actual innocence or constitutional error by clear and convincing evidence. The motion for a stay of execution was overruled as moot. View "Prosecuting Attorney, 21st Judicial Circuit, ex rel. Williams v. State of Missouri" on Justia Law

In 1997, John Doe pleaded guilty to two class C felonies: deviate sexual assault in the first degree and sexual assault in the first degree. He was placed on probation for five years and registered as a sex offender under the Missouri Sex Offender Registry Act (MO-SORA). After completing probation in 2002, his criminal records were sealed. Despite this, Doe remained on the sex offender registry. Over the years, MO-SORA was amended to include more stringent requirements, such as public disclosure of registrants' information, in-person reporting, and lifetime registration for certain offenses.Doe filed a petition for declaratory and injunctive relief in the Circuit Court of St. Louis County, arguing that the amendments to MO-SORA violated his substantive due process rights and constituted an ex post facto law. The circuit court ruled against Doe on all claims, leading to his appeal.The Supreme Court of Missouri reviewed the case and affirmed the lower court's judgment. The court held that Doe has no fundamental right to privacy in the information required by the registry, as the information was already public before his records were sealed. The court found that MO-SORA is rationally related to the legitimate state interest of protecting children and public safety. Additionally, the court determined that MO-SORA is civil in nature and does not constitute a punitive ex post facto law. The court concluded that the registration requirements, including lifetime registration and in-person reporting, are not excessive and serve the non-punitive purpose of public safety. Therefore, the court upheld the constitutionality of MO-SORA's registration requirements. View "Doe v. Olson" on Justia Law

Marcellus Williams was convicted of first-degree murder and sentenced to death following a jury trial. His conviction and sentence were affirmed by the Supreme Court of Missouri, and his postconviction relief was denied. Williams sought additional DNA testing through a habeas corpus petition, which led to a temporary stay of execution and the appointment of a special master to oversee the testing. The results did not demonstrate his innocence, and his habeas petition was denied. Subsequent petitions for writs of habeas corpus and declaratory judgment were also denied.The St. Louis County prosecutor filed a motion to vacate Williams' conviction and death sentence, citing potential actual innocence based on DNA evidence, ineffective assistance of counsel, and racial discrimination in jury selection. This motion remains pending in the circuit court. Despite this, the Supreme Court of Missouri issued a warrant of execution for Williams, setting a new execution date.The Supreme Court of Missouri reviewed Williams' motion to withdraw the warrant of execution, arguing that the prosecutor's motion constituted a state postconviction motion, which should bar setting an execution date. The court found that Rule 30.30(c) only refers to postconviction motions filed by the defendant, not the prosecutor. Since Williams had already exhausted his state postconviction remedies, the court held that the execution date was properly set. The court also noted that the pending prosecutor's motion did not automatically warrant a stay of execution and that Williams had not demonstrated the necessary factors for equitable relief. Consequently, the court overruled Williams' motion to withdraw the warrant of execution. View "State v. Williams" on Justia Law

Shawn Flaherty was convicted of second-degree domestic assault and armed criminal action following a violent altercation with his wife, during which he brandished a revolver and a bullet from the weapon struck his wife in the knee. Flaherty's defense at trial was that the shooting was accidental, and his counsel requested an instruction for the lesser-included offense of second-degree domestic assault, which the jury ultimately found him guilty of. Flaherty was sentenced to seven years for the assault count and three years for the armed criminal action count, to be served consecutively. His convictions were affirmed on direct appeal.Flaherty subsequently filed a motion for postconviction relief, arguing that his trial counsel was ineffective for failing to request a lesser-included instruction for fourth-degree domestic assault. The motion court overruled Flaherty’s motion after an evidentiary hearing, finding that while his trial counsel's performance was constitutionally deficient for failing to request the instruction for fourth-degree domestic assault, this did not prejudice Flaherty.The Supreme Court of Missouri affirmed the motion court's judgment. The court found that there was sufficient evidence to support the motion court’s finding that counsel’s failure to request the lesser-included instruction for fourth-degree assault did not prejudice Flaherty. The court also noted that the motion court judge, who had also presided over Flaherty's criminal trial, was in a better position to assess the impact of the evidence on the jury and whether it was reasonably likely the jury would have been persuaded by arguments that Flaherty's acts were merely criminally negligent. View "Flaherty v. State" on Justia Law

The case revolves around a dispute over a change of judge in a criminal proceeding. The defendant was charged with a felony, and the original judge recused himself. A new judge was assigned, but the defendant and the prosecutor jointly stipulated to a change of venue and judge. The case was transferred to Butler County and assigned to Judge Pritchett. After Judge Pritchett's retirement, the case was reassigned to Judge Proctor. The defendant then filed a motion for a change of judge, which Judge Proctor sustained. The Attorney General of Missouri, acting as the special prosecutor, filed a petition for a writ of prohibition or mandamus, arguing that the circuit court lacked the authority to sustain the defendant's motion for a change of judge.The court of appeals issued a permanent writ of prohibition and transferred the case to the Supreme Court of Missouri. The defendant did not file a brief but conceded to the Attorney General's writ of prohibition, requesting the case to be reassigned to Judge Proctor for final disposition.The Supreme Court of Missouri found that the defendant's stipulation to a change of venue and judge precluded the circuit court from sustaining the defendant's subsequent motion for a change of judge. The defendant did not allege or show a change of judge was required due to "fundamental fairness" or because Judge Proctor was related to the defendant, had an interest in the case, had been counsel in the proceedings, or disqualified for any other reason. The court concluded that Judge Proctor lacked the authority to sustain the defendant's motion for a change of judge. The court issued a permanent writ of prohibition barring the circuit court from enforcing the order sustaining the defendant's second change of judge. The case remains assigned to Judge Proctor. View "State ex rel. Bailey v. Pierce" on Justia Law

The case involves Robert Anthony Woolery, who was convicted of two counts of delivery of a controlled substance. In 2021, the Sedalia police department identified Woolery as a subject of interest in their investigation into low-to-mid-level drug dealers. The police organized two "controlled buys" from Woolery, using a confidential informant. The transactions were recorded, and the informant produced a bag containing methamphetamine after each buy. Woolery was subsequently charged and convicted.Woolery appealed his conviction, raising five points. He argued that the circuit court erred in not appointing counsel at his initial appearance, in not preserving a transcript or recording of his arraignment, in sentencing him to imprisonment rather than ordering a mental examination, and in overruling his motion to suppress evidence. He also claimed that the detectives lacked authority to respond to emergency situations outside the Sedalia city limits.The Supreme Court of Missouri affirmed the circuit court's decision. The court found that Woolery was not entitled to counsel during his initial appearance and arraignment, either through Rule 31.02(a) or the Sixth Amendment. The court also found that the absence of a transcript or recording of Woolery’s November 15 appearance did not hamper its ability to meaningfully review the points raised by Woolery. The court further held that Woolery failed to establish that manifest injustice or a miscarriage of justice resulted from his sentencing. Finally, the court found that Woolery's claim regarding the denial of his motion to suppress was not preserved for appellate review. View "State of Missouri vs. Woolery" on Justia Law

The case revolves around Troy Jackson-Bey, who was convicted of five counts, including first-degree murder and first-degree assault, following an altercation at a residence. The altercation began when Jackson-Bey and another man argued over a parking issue. Jackson-Bey shot the man, who later died from his injuries. Jackson-Bey then forced his way into the man's home, where he fired his weapon multiple times during a struggle with the man's wife. The wife was not shot. Jackson-Bey appealed his conviction, challenging the admission of surveillance video, the submission of the verdict director for first-degree assault, and the sufficiency of evidence supporting his convictions.The Circuit Court of the City of St. Louis had previously ruled against Jackson-Bey's motion to exclude surveillance video taken from the residence. The court also found there was sufficient evidence supporting Jackson-Bey’s convictions. Jackson-Bey appealed these decisions.The Supreme Court of Missouri affirmed the lower court's decisions. The court found that the circuit court did not err in admitting the surveillance video, as the rule of completeness did not apply. The court also ruled that there was sufficient evidence to support Jackson-Bey’s first-degree assault conviction, as the jury could have reasonably found that Jackson-Bey attempted to kill or cause serious physical injury to the wife. Lastly, the court concluded that age is not an element of the offense of first-degree murder, and thus, it was not necessary for the state to prove Jackson-Bey was 18 years or older at the time of the offense. View "State of Missouri v. Jackson-Bey" on Justia Law

Ashley Colville was charged with second-degree involuntary manslaughter following a motor vehicle accident in St. Louis, Missouri, in which Rodney Larue was fatally injured. The indictment alleged that Colville caused Larue's death by colliding with his vehicle and did so with criminal negligence by failing to yield and use a turn signal. Colville filed a motion to dismiss the indictment, arguing it was insufficient because it failed to state the offense charged.The Circuit Court of St. Louis dismissed the indictment with prejudice. The court held that Colville's alleged failure to yield and signal did not amount to criminal negligence, an essential element of second-degree involuntary manslaughter. The court based its decision on a review of several exhibits, including a video surveillance recording of the accident, and concluded that Colville's actions did not constitute a "gross deviation" that could legally be found criminally negligent.The Supreme Court of Missouri vacated the lower court's judgment and remanded the case for further proceedings. The Supreme Court held that the lower court erred in dismissing the indictment because it was sufficient in all required respects. The court clarified that at the motion to dismiss stage, the court's review of an indictment is limited to determining whether the indictment contains the essential elements of the offense and whether it apprises the defendant of facts constituting the charge. The court found that the indictment against Colville met these requirements. The court also noted that whether the state has satisfied its burden in proving Colville committed the offense charged is not capable of determination without a trial. View "State of Missouri vs. Colville" on Justia Law