Justia Criminal Law Opinion Summaries

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

The case involves Lorandis Phillips, who was convicted of first-degree robbery and second-degree assault. The incident occurred on December 14, 2018, when Phillips and three other men attacked a man in a shed behind Phillips' house. The victim was struck in the head, causing him to fall and lose consciousness briefly. The men then stole his cell phone, wallet, and car keys. Phillips was arrested and charged with the crimes.Phillips appealed his conviction, raising seven points. He argued that he was not represented by counsel at an appearance prior to his preliminary hearing, that the court failed to preserve a recording or transcript of that appearance, that the court erred in allowing his felony information to be amended, that there was insufficient evidence to support a conviction on the robbery count, and that there was a deficiency in the amended information for the assault count.The Supreme Court of Missouri affirmed the lower court's decision. The court found that Phillips' lack of counsel at his initial appearance did not constitute plain error, as he had not shown that he was prejudiced by the absence of counsel. The court also found that the lower court did not err in allowing the felony information to be amended, as the amendment did not prejudice Phillips' substantial rights. The court further found that there was sufficient evidence to support the robbery conviction, and that any deficiency in the amended information for the assault count did not prejudice Phillips. View "State v. Phillips" on Justia Law

The case revolves around James Logan, who was convicted of three misdemeanor offenses: first-degree trespass, fourth-degree assault, and peace disturbance. These offenses occurred at a Mexican restaurant in Columbia, where Logan was seen yelling at customers and causing a disturbance. Despite being previously warned by the restaurant owner and the police, Logan continued his disruptive behavior, leading to a physical altercation with the owner. Logan was later arrested and charged with the aforementioned misdemeanors.Logan was initially denied bond due to his perceived danger to the community. However, he was later released on his own recognizance, subject to conditions including completion of a substance use treatment program and refraining from committing new offenses. Logan violated these conditions by committing additional offenses and failing to complete the treatment program. His release was subsequently revoked.The Circuit Court of Boone County found Logan guilty of all charges and sentenced him to jail time and probation, which included participation in a mental health treatment program. Logan appealed his convictions, arguing that his right to counsel was violated and that the evidence was insufficient to support his convictions.The Supreme Court of Missouri, however, chose to apply the escape rule, which denies the right of appeal to a defendant who evades justice. The court found that Logan's repeated failure to appear for his probation revocation hearing and his commission of additional criminal offenses during this period adversely affected the criminal justice system. Therefore, the court dismissed Logan's appeal. View "State of Missouri vs. Logan" on Justia Law

The case involves Tiffany Mills, who was convicted for third-degree assault and armed criminal action. Mills had a confrontation with a woman (the victim) who was friends with her boyfriend. The confrontation escalated into a physical fight, during which Mills stabbed the victim seven times. Mills claimed self-defense, stating that the victim attacked her first. The victim suffered severe injuries, including a lacerated spleen, a partially collapsed lung, and significant blood loss.The case was initially heard in the Circuit Court of Jackson County, where Mills was found guilty of third-degree assault and armed criminal action. Mills appealed her conviction, arguing that the circuit court erred in failing to hold a jury-tried punishment stage, excluding certain evidence during the trial, and failing to appoint counsel at her initial appearance before the court.The Supreme Court of Missouri reviewed the case and found no error in the lower court's judgment. The court held that Mills had validly waived her right to jury sentencing when she requested the judge to determine her punishment. The court also found that the circuit court did not abuse its discretion in excluding evidence of specific instances of the victim's violent behavior. Lastly, the court held that a proceeding during which the circuit court considers or determines conditions for pretrial release is not a critical stage requiring the presence of counsel. Therefore, the court affirmed the circuit court's judgment. View "State of Missouri, Respondent, vs. Tiffany Mills, Appellant." on Justia Law

On December 13, 2023, the Supreme Court of Missouri issued an execution warrant for Brian Dorsey, who is serving a death sentence for two counts of first-degree murder. Subsequently, Dorsey filed two petitions for writ of habeas corpus, arguing that he is innocent as he was incapable of deliberation due to drug-induced psychosis at the time of the offenses, that his trial counsel was ineffective due to a conflict of interest resulting from a flat-fee arrangement, and that his execution would violate the Eighth Amendment as he belongs to a unique class of persons for whom the penological goals supporting capital punishment are no longer met.The Court found that Dorsey failed to present any legally cognizable claims for habeas relief. He did not deny committing the murders and failed to establish that he was actually innocent of first-degree murder. The Court had previously found Dorsey's claim of ineffective assistance of counsel due to a conflict of interest to be without merit, and he was procedurally barred from raising this claim again. Lastly, Dorsey's Eighth Amendment claim was deemed without merit and was interpreted as a plea for clemency, which is beyond the Court's review and authority. Therefore, both petitions for writ of habeas corpus were denied. View "State ex rel. Dorsey vs. Vandergriff" on Justia Law