Justia Criminal Law Opinion Summaries

Articles Posted in Supreme Court of Missouri
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The Supreme Court vacated the judgment of the motion court overruling Appellant's pro se Rule 29.15 postconviction motion seeking to vacate his felony statutory sodomy conviction under Mo. Rev. Stat. 566.062, holding that there was no final judgment in the underlying criminal case, and therefore, Appellant's postconviction relief motion was premature. In his motion for postconviction relief, Appellant argued that he received ineffective assistance of trial counsel. After an evidentiary hearing, the motion court overruled the motion on the merits. Appellant appealed, arguing that his postconviction relief motion was premature because the trial court failed to carry out the Supreme Court's mandate issued in his direct appeal, and therefore, his judgment of conviction was not yet final. The Supreme Court agreed, holding (1) the trial court failure strictly to comply with the Court's mandate; and (2) therefore, the judgment of condition in Appellant's criminal case was not yet a final judgment that triggers the running of the time period in which he can file a Rule 29.15 motion, and the Rule 29.15 motion was premature. View "Lemasters v. State" on Justia Law

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The Supreme Court reversed the judgment of the circuit court overruling Appellant's Rule 24.035 motion for postconviction relief from the sentences imposed on her for class C felony stealing under Mo. Rev. Stat. 570.030, holding that Appellant's crimes were class A misdemeanors under State v. Bazell, 497 S.W.3d 263 (Mo. banc 2016), and Appellant should have been sentenced accordingly. Appellant's judgment of conviction was not yet final when the Supreme Court decided Bazell, which held that stealing in violation of section 570.030 is a class A misdemeanor that cannot be enhanced to a class C felony. After Bazell was decided, Appellant's two five-year sentences were imposed. Appellant argued that she was entitled to have Bazell applied to her sentencing and that the sentences imposed exceeded the sentences authorized by law. The Supreme Court agreed, holding (1) Appellant was entitled to have Bazell applied to her sentencing; and (2) therefore, the circuit court erred in entering judgments of conviction against Appellant and sentencing her as if her crimes were class C felonies. View "Hamilton v. State" on Justia Law

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The Supreme Court reversed the judgment of the circuit court sentencing Appellant for class C felony stealing under Mo. Rev. Stat. 570.030 because State v. Bazell, 497 S.W.3d 263 (Mo. banc 2016), held that stealing in violation of section 570.030 is a class A misdemeanor that cannot be enhanced to a felony. Appellant pleaded guilty to stealing in violation of section 570.030. Before Appellant's sentencing occurred Bazell was decided. Bazell held that stealing under section 570.030.1 was a class A misdemeanor that could not be enhanced to a class C felony. The circuit court subsequently sentenced Appellant to seven years for a class C felony, despite Appellant's objection that Bazell required he be sentenced for a class A misdemeanor. In his direct appeal, Appellant argued that he received an excessive sentence. The Supreme Court agreed, holding (1) Appellant did not waive his claim that he received an excessive sentence; and (2) the circuit court erred in sentencing Appellant for a class C felony. View "State v. Russell" on Justia Law

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The Supreme Court denied Petitioner's petition for a writ of habeas corpus, holding that Petitioner's claims of actual innocence did not entitle him to relief and that Petitioner neither demonstrated the "substantial threshold showing of insanity" nor that he was incompetent under Mo. Rev. Stat. 552.060. Petitioner was convicted of murder and sentenced to death. After the Supreme Court issued its order setting Petitioner's execution date, Petitioner filed his petition for writ of habeas corpus. The Supreme Court denied relief, holding (1) Petitioner failed to prove the substantial threshold showing of insanity required by Panetti v. Quarterman, 551 U.S. 930 (2007) and Ford v. Wainwright, 477 U.S. 399 (1986); (2) Petitioner failed to prove that he is incompetent under section 552.060; and (3) Petitioner failed to offer sufficient evidence to show actual innocence, either as a gateway or as a freestanding claim. View "State ex rel. Barton v. Stange" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court judgment overruling Defendant's Mo. Rev. Stat. 29.15 motion for postconviction relief from his death sentence for first degree murder, holding that the circuit court's findings of fact and conclusions of law were not clearly erroneous. On appeal, Defendant argued that the circuit court committed multiple errors affecting the guilt phase, penalty phase, and postconviction relief phases of his criminal case. Among other things, Defendant argued that the circuit court erred in failing to find that his counsel provided ineffective assistance in several respects. The Supreme Court affirmed, holding that the circuit court's findings of fact and conclusions of law were not clearly erroneous and that the circuit court did not err in denying postconviction relief. View "McFadden v. State" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court committing Appellant to the department of mental health (DMH) as a sexually violent predator (SVP), holding that the circuit court did not err. In 2005, Appellant pleaded guilty to felony sex abuse. Before his release in 2016, the State filed a petition seeking to civilly commit him as an SVP. A jury found Appellant to be an SVP and the circuit court committed him to DMH. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion when it prohibited Appellant from questioning the jury panel about the specific ages of child victims; (2) the circuit court did not err when it excluded a portion of the testimony regarding Appellant's risk of future dangerousness; (3) the circuit court did not plainly err in submitting Instruction No. 6, the verdict director; (4) Appellant received effective assistance of counsel at his probable cause hearing; (5) the circuit court did not plainly err in overruling Appellant's motion for new trial based on juror nondisclosure of bias; (6) Appellant's claim of ineffective assistance of counsel for failure to move for change of venue was without merit; and (7) omissions in the trial transcript did not prejudice Appellant's appellate review. View "In re Care & Treatment of D.N." on Justia Law

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The Supreme Court affirmed the judgment of the circuit court sentencing Defendant to two terms of life imprisonment without the possibility of parole, holding that Mo. Rev. Stat. 565.020 is constitutional as applied to Defendant. Defendant was nineteen years old when he killed his grandparents. Defendant was convicted of two counts of first-degree murder and sentenced to death for each murder count. Later, a federal district court ordered the state of Missouri either to sentence Defendant to life without the possibility of probation or parole or grant him a new penalty phase trial. On remand, Defendant argued that section 565.020, which then provided that first-degree murder shall be punishable either by death or imprisonment for life without eligibility for probation or parole, was unconstitutional as applied to him because offenders who commit crimes at nineteen years old also display the transient, hallmark features of adolescence affecting risk and impulse control. The circuit court rejected Defendant's claims and sentenced him to life without the possibility of parole on both murder counts. The Supreme Court affirmed, holding that where Supreme Court precedent clearly defines a juvenile as an individual younger that eighteen years of age for purposes of the considerations Defendant sought, section 565.020 was constitutional as applied to Defendant. View "State v. Barnett" on Justia Law

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The Supreme Court dismissed Appellant's appeal challenging his convictions for first-degree statutory sodomy and attempted first-degree statutory sodomy, holding that, because two counts as to which the jury could not reach of verdict remained pending, the circuit court's judgment was not final. A jury convicted Appellant of the two sodomy charges but could not reach a verdict on the charges for first-degree statutory rape and incest. The circuit court declared a mistrial as to the rape and incest charges. The court then entered a judgment disposing of and imposing sentences on the two sodomy charges. The judgment, however, was silent as to the two counts on which the court had ordered a mistrial. Appellant appealed. The Supreme Court dismissed the appeal, holding that because Appellant was charged with four counts and two of those counts remained pending before the circuit court, the court's judgment of conviction on only two of the counts was not final for purposes of appeal. View "State v. Waters" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court sustaining the chairman of the Missouri board of probation and parole's motion to dismiss Appellant's petition for declaratory judgment in which he sought a declaration of his right to a parole hearing, holding that the repeal of Mo. Rev. Stat. 195.295.3 did not render Appellant parole eligible. In 2013, a jury found Appellant guilty of drug trafficking in the second degree for acts committed in 2009. Defendant was sentenced under section 195.295.3 as a prior drug offender to a term of imprisonment without eligibility for parole. After the general assembly repealed section 195.295 in January 2017, Appellant filed his petition for declaratory judgment arguing he was eligible for parole because the statute that had rendered him parole ineligible had been repealed. The circuit court dismissed the petition, concluding that the repeal of the statute could not be applied retroactively because it would alter Appellant's sentence. The Supreme Court affirmed, holding that because Appellant's parole ineligibility was part of his sentence, the repeal of section 195.295.3 did not render him eligible for parole. View "Mitchell v. Phillips" on Justia Law

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The Supreme Court reversed the judgment of the circuit court sustaining Respondent's motion for judgment on the pleadings and granting Respondent a hearing on his single-count petition for declaratory judgment claiming his parole eligibility should no longer be governed by Mo. Rev. Stat. 195.295 and releasing Respondent on parole, holding that the repeal of section 195.295 had no effect on Respondent's parole eligibility. Respondent was found guilty of trafficking drugs in the second degree for acts committed in May 2006. Respondent was sentenced as a prior drug offender to twenty-five years' imprisonment without eligibility for parole under section 195.295. On January 1, 2017, section 195.295 was repealed. At issue was the legal effect section 195.295's repeal had on Respondent's eligibility for parole. The Supreme Court held that, for the reasons set forth in Mitchell v. Jones, __ S.W.3d __, also decided today, Respondent was not eligible for parole. View "Woods v. Missouri Department of Corrections" on Justia Law