Justia Criminal Law Opinion Summaries

After a bench trial, the appellant was convicted of first-degree murder and armed criminal action for the death of her husband. She was sentenced to life without parole and 30 years to be served concurrently. While her direct appeal was still pending, she filed a pro se motion under Missouri Supreme Court Rule 29.15 to set aside her conviction. The circuit court later appointed counsel for her postconviction proceeding. After the Missouri Court of Appeals affirmed her conviction and issued its mandate, appointed counsel entered an appearance but did not file an amended motion until after the deadline established by Rule 29.15.The Circuit Court of Douglas County found both the pro se and amended motions were untimely but determined appointed counsel had abandoned the appellant by failing to timely file the amended motion. The court proceeded to deny relief on the merits of the ineffective assistance of counsel claims asserted in the amended motion, including failure to call an expert on psychological shock and failure to request a competency evaluation, without holding an evidentiary hearing.The Supreme Court of Missouri reviewed the appeal. It held that the pro se motion was timely under the applicable version of Rule 29.15, as it was deemed filed immediately after the appellate mandate. However, the amended motion was untimely. The Court concluded the motion court properly found abandonment by appointed counsel, as the tardiness was solely counsel’s fault and supported by the record. In such cases, the amended motion should be treated as timely and the court may review its merits without remand for an abandonment hearing.On the merits, the Supreme Court of Missouri held the motion court did not clearly err in denying both ineffective assistance claims without an evidentiary hearing because the record refuted any showing of prejudice or need for further factual development. The judgment denying postconviction relief was affirmed. View "Young vs. State" on Justia Law

The case concerns an incident in July 2021 involving John Otis, a victim, and a minor child. Otis became angry while riding in a vehicle, leading to a series of violent acts. After initially driving away, Otis returned and struck the victim twice with the car, pinning her against a gas station building. He then assaulted her with a metal pole, punched her, and stomped on her until she lost consciousness. The child was present throughout the events and remained with the victim until help arrived. The victim suffered severe injuries and was hospitalized.The State charged Otis with three counts of first-degree domestic assault, armed criminal action, and endangering the welfare of a child. The Circuit Court of St. Charles County found Otis to be a persistent offender based on prior felony convictions in Missouri and Illinois, and sentenced him to life in prison for each domestic assault count, 15 years for armed criminal action, and seven years for endangering the welfare of a child. The sentences were ordered to run consecutively. A jury found Otis guilty of all charges. Otis appealed, challenging the persistent offender determination, the sufficiency of evidence supporting that finding, and the jury instructions.The Supreme Court of Missouri reviewed Otis’s appeal. The Court held that although recent U.S. Supreme Court precedent in Erlinger v. United States requires a jury, not a judge, to decide facts that increase penalty ranges, Otis’s claim was not preserved and did not warrant plain error review because he failed to demonstrate manifest injustice. The Court found sufficient evidence supported Otis’s persistent offender status, particularly regarding the Illinois felony conviction. It also declined to review the jury instruction claim for plain error. The Supreme Court of Missouri affirmed the circuit court’s judgment. View "State vs. Otis" on Justia Law

The case concerns an incident in which the defendant, alongside two accomplices, confronted a victim outside his home, robbed him at gunpoint, and shot him multiple times. The victim survived after extensive medical treatment and identified the defendant in a police lineup. The defendant was charged with several offenses, including first-degree robbery, first-degree assault, armed criminal action, second-degree burglary, and stealing. At trial, the court granted the defendant’s motion for acquittal on the burglary and stealing charges, and the jury found him guilty on the remaining four counts.Following the jury verdict, the Circuit Court of the City of St. Louis held a sentencing hearing. During this proceeding, the court referenced the defendant’s prior involvement in an unrelated carjacking case, in which the defendant had been acquitted of all charges that were not dismissed. Defense counsel did not object to these remarks. The court ultimately sentenced the defendant to consecutive prison terms totaling fifty years. The defendant appealed, arguing that the circuit court committed plain error by considering conduct from the acquitted charges without proof by a preponderance of the evidence.The Supreme Court of Missouri reviewed the defendant’s claim under the plain error standard because it was not preserved by objection at sentencing. The court held that the circuit court did not commit plain error in referencing the defendant’s prior acquittals, finding that the judge’s remarks were insufficient to show the sentence was based on unproven conduct. The court distinguished prior case law limiting the consideration of acquitted conduct to jury sentencing and found no manifest injustice. The Supreme Court of Missouri affirmed the circuit court’s judgment. View "State vs. Harris" on Justia Law

James Guthrie was charged with multiple counts of sexual offenses involving two victims. Relevant to this appeal, one count alleged that Guthrie committed first-degree statutory rape against Victim 2, specifically that he knowingly had sexual intercourse with her when she was less than fourteen years old. At trial, Victim 2 testified that the incident occurred in 2017, and though she initially indicated it happened when she was 14, she also described herself as a “preteen” at the time. The defense argued that the evidence was insufficient to prove the offense took place before Victim 2 turned fourteen.After a jury trial in the Circuit Court of Mississippi County, Guthrie was found guilty on all counts. He appealed, contending that the evidence did not establish beyond a reasonable doubt that Victim 2 was under fourteen when the offense occurred. The Missouri Court of Appeals initially reviewed the case, and then the Supreme Court of Missouri accepted transfer and exercised jurisdiction.The Supreme Court of Missouri held that, under the standard requiring the court to view evidence and reasonable inferences in the light most favorable to the verdict, the jury was permitted to credit Victim 2’s testimony that she was a “preteen” at the time of the incident, which by definition means younger than thirteen. The Court found that this testimony provided sufficient evidence that the crime occurred before Victim 2 turned fourteen, as required by statute. The Court rejected arguments that conflicting testimony or the lack of precise dates undermined the verdict, and it noted that no due process or instructional challenges were preserved. Accordingly, the Supreme Court of Missouri affirmed the conviction and the judgment of the circuit court. View "State vs. Guthrie" on Justia Law

The appellant was charged with driving while intoxicated in 2021 and the state sought to enhance his sentence by establishing that he was a chronic offender, which requires proof of four or more prior intoxication-related traffic offenses (IRTOs). To support this, the state introduced evidence of four prior offenses, including a 2002 municipal conviction for “driving while intoxicated” under the Joplin city code. The appellant contested the use of this 2002 offense, arguing the evidence did not prove beyond a reasonable doubt that it involved physically driving or operating a vehicle, as required by Missouri law at the time of the current offense.The Circuit Court of Jasper County admitted the 2002 municipal conviction into evidence and found the appellant to be a chronic offender, determining all four prior offenses qualified as IRTOs. The appellant was subsequently convicted by a jury for the current driving while intoxicated offense and sentenced as a chronic offender to seven years’ imprisonment. He appealed, arguing that only three of his prior offenses qualified as IRTOs and that he should have been sentenced as an aggravated offender rather than a chronic offender.The Supreme Court of Missouri reviewed the sufficiency of the evidence de novo. It held that the state failed to prove beyond a reasonable doubt that the 2002 municipal offense involved physically driving or operating a vehicle, since the record was silent as to the conduct underlying the offense and there was no evidence as to the elements of the municipal ordinance. Consequently, the court vacated the judgment sentencing the appellant as a chronic offender and remanded the case for resentencing as an aggravated offender. View "State v. Peters" on Justia Law

Late at night, a police officer in Jefferson City observed a vehicle behaving suspiciously in a closed business area known for crime. The officer stopped the vehicle, which was driven by James Eggleston with a female passenger. The passenger appeared to be under the influence of narcotics, and Eggleston volunteered that he had an outstanding warrant and did not consent to a search of the vehicle. After arresting Eggleston, the officer contacted a canine unit. The canine alerted to the driver's side, leading officers to search the vehicle and find a bottle containing four baggies of methamphetamine within easy reach of the driver's seat. Additional drug paraphernalia and the passenger’s identification were found on the passenger side.The State charged Eggleston with possession of a controlled substance in violation of Missouri law. Following a bench trial in the Circuit Court of Cole County, the judge found Eggleston guilty and sentenced him to three years in prison. Eggleston appealed, arguing that the evidence was insufficient to prove he knowingly possessed the methamphetamine, particularly since it was in a shared compartment and could have belonged to the passenger.The Supreme Court of Missouri reviewed the case, applying the statutory definitions of “knowingly” and “possessed” and clarifying that joint possession does not require “additional incriminating evidence” beyond proximity and control. The court held that circumstantial evidence, including the methamphetamine’s location within Eggleston’s reach, his conduct, and other contextual facts, was sufficient for a rational factfinder to conclude he knowingly possessed the controlled substance. The Supreme Court of Missouri affirmed the circuit court’s judgment, holding that the conviction was supported by sufficient evidence and rejecting prior case law that imposed heightened burdens in joint possession cases. View "State of Missouri vs. Eggleston" on Justia Law

Amanda Rogers was convicted of unlawful possession of a firearm by a felon after an incident in which she drove a vehicle with a passenger, Seller, who attempted to sell a gun to Informant. Informant notified law enforcement after Seller, a known felon, tried to sell him a firearm and could not provide proof of ownership. Rogers drove Seller to meet Informant; after the attempted sale, Informant described the vehicle, its occupants, and its direction to law enforcement. Trooper Enderle located the vehicle, initiated a stop after backup arrived, and found Rogers acting suspiciously. A subsequent search revealed compatible ammunition on the driver’s side and a firearm within easy reach of both front seats. Rogers denied knowledge of a firearm and refused consent to search. After a canine unit arrived, law enforcement found the firearm in a bucket between the seats.The Circuit Court of Polk County, following a jury verdict of guilty, sentenced Rogers to seven years’ imprisonment and placed her in a long-term treatment program. Rogers moved to suppress the firearm and ammunition, arguing lack of probable cause for the stop and insufficient evidence of knowing possession. The circuit court denied both motions. She appealed, raising the same issues, and the Missouri Court of Appeals reviewed the case before the Supreme Court of Missouri granted transfer.The Supreme Court of Missouri held that the state presented sufficient evidence for a reasonable factfinder to conclude Rogers knowingly possessed the firearm, applying statutory definitions of possession and knowledge, and rejected the requirement for “additional incriminating evidence” in joint possession cases. The Court also found that Trooper Enderle had probable cause to search the vehicle, based on Informant’s tip, corroborating circumstances, and Rogers’ conduct. The judgment of the circuit court was affirmed. View "State of Missouri vs. Rogers" on Justia Law

Craig M. Wood was convicted of abducting and murdering 10-year-old Hailey Owens in Springfield, Missouri. After eyewitnesses reported the abduction and provided Wood’s license plate number, police traced it to Wood's residence. Upon searching his home, officers found Hailey’s body in the basement, along with evidence of sexual assault and materials indicating Wood’s sexual interest in young girls. Wood was tried and found guilty of first-degree murder and sentenced to death.The Circuit Court of Greene County presided over Wood’s jury trial, entered judgment, and imposed the death sentence after the jury found multiple aggravating circumstances. The Supreme Court of Missouri previously affirmed Wood’s conviction and sentence on direct appeal in State v. Wood, 580 S.W.3d 566 (Mo. banc 2019). Wood then filed a Rule 29.15 motion for postconviction relief, arguing ineffective assistance of counsel on numerous grounds related to evidence, trial strategy, and mitigation. The motion court held an evidentiary hearing and denied the motion, finding no basis for relief.On appeal to the Supreme Court of Missouri, Wood raised 22 points concerning counsel’s performance and other alleged errors. The court reviewed whether the motion court’s findings and conclusions were clearly erroneous, applying the standard set forth in Rule 29.15(k). The Supreme Court of Missouri held that none of Wood’s claims demonstrated deficient performance or prejudice under the Strickland v. Washington standard. The court found the motion court’s factual determinations and legal conclusions were not clearly erroneous and affirmed the denial of postconviction relief. The judgment overruling Wood’s Rule 29.15 motion was affirmed. View "Wood vs. State of Missouri" on Justia Law

Richard James Johnson was charged with three moving violations in Missouri, including a class E felony charge for driving while intoxicated (DWI) as a persistent offender. The persistent offender charge was based on Johnson’s alleged prior DWI convictions on two separate occasions. Johnson argued that, under recent Supreme Court precedent, any fact that could increase the range of punishment—such as whether prior DWI convictions occurred on separate occasions—must be determined by a jury, not solely by a judge.The Circuit Court of Franklin County agreed with Johnson and dismissed the class E felony DWI charge, finding that the statute governing persistent offender status violated Johnson’s Fifth and Sixth Amendment rights by not requiring a jury determination of the “separate occasions” element. The State sought review from the Missouri Court of Appeals, which denied its writ petition. The State then sought relief from the Supreme Court of Missouri, which issued a preliminary writ of prohibition.The Supreme Court of Missouri reviewed whether section 577.023.2, which assigns the fact-finding responsibility for persistent offender status to the trial judge, is facially unconstitutional. The court held that the statute is not facially unconstitutional because it is possible for the jury to determine the relevant facts in accordance with constitutional requirements. The statute can be applied constitutionally if, after the judge’s initial finding, the jury also finds beyond a reasonable doubt that the defendant is a persistent offender. Therefore, the circuit court lacked authority to dismiss the felony charge on facial constitutional grounds. The Supreme Court of Missouri made permanent its preliminary writ of prohibition, ordering the circuit court to set aside its dismissal of the class E felony DWI charge. View "State ex rel. Catherine Hanaway vs. Hellmann" on Justia Law

Richard Neil Burkett was involved in a physical altercation with his brother-in-law at a convenience store in Texas County, Missouri. Witnesses stated that after being separated from his brother-in-law, Burkett pointed a semiautomatic handgun at him, threatened him, and pulled the trigger, although the gun did not fire. Burkett gave several inconsistent accounts to law enforcement, at first denying having a gun, then claiming self-defense, and finally admitting to pointing the gun after the fight was over. At trial, Burkett’s defense was that he never intended to harm his brother-in-law and only sought to scare him, arguing his gun was unloaded and he lacked intent to injure.The Circuit Court of Texas County conducted a jury trial, where Burkett was found guilty of first-degree assault and armed criminal action. During trial, Burkett did not request a self-defense instruction nor object to the jury instructions, and his counsel did not object to the State’s closing argument, which inaccurately stated that intent was not required for first-degree assault. Burkett’s post-trial motion did not raise these issues.The Supreme Court of Missouri reviewed Burkett’s appeal, in which he requested plain error review on two grounds: the lack of a self-defense instruction and the absence of a curative instruction after the State’s misstatement of law in closing argument. The court held that although Burkett may have injected self-defense into the case through his testimony, he failed to request the instruction or object to its absence, and his trial strategy was inconsistent with self-defense. Similarly, Burkett did not object to the State’s closing argument or request a curative instruction. The Supreme Court of Missouri exercised its discretion to decline plain error review for both claims and affirmed the judgment of the circuit court. View "State v. Burkett" on Justia Law