Justia Criminal Law Opinion Summaries

Articles Posted in Supreme Court of Missouri
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The Supreme Court affirmed the judgment of the circuit court convicting Defendant of tampering with a judicial officer and second-degree harassment of his probation officer, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) Defendant's facial overbreadth challenge to the second-degree harassment statute, Mo. Rev. Stat. 565.091, was without merit; (2) there was sufficient evidence to support Defendant's conviction for second-degree harassment; and (3) the district court did not violate Defendant's right to be free from double jeopardy when it sentenced Defendant for both tampering with a judicial officer and second-degree harassment. View "State v. Collins" on Justia Law

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The Supreme Court vacated the judgment of the circuit court convicting Defendant for driving while intoxicated and sentencing him as a habitual offender, holding that the circuit court erred in sentencing Defendant as a habitual offender.On appeal, Defendant argued that the State failed to prove he was a habitual offender based solely on a certified copy of his Colorado driving record. Specifically, Defendant argued that the State failed to introduce facts underlying the Colorado convictions to show that the conduct at issue would qualify as intoxication-related traffic offenses (IRTOs) in Missouri at the time of his current offense. The Supreme Court vacated the judgment, holding that the State failed to prove beyond a reasonable doubt that Defendant was convicted of at least five prior IRTOs based solely on his Colorado driving record. View "State v. Shepherd" on Justia Law

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The Supreme Court vacated the judgment of the circuit court convicting Defendant of assault and armed criminal action following a jury trial, holding that the circuit court prejudicially erred in failing to give the "castle doctrine" self-defense jury instruction that Defendant requested.During trial, Defendant requested a self-defense instruction justifying the use of deadly force by a person lawfully in a vehicle, otherwise known as the "castle doctrine." The circuit court refused the castle doctrine instruction but gave the general self-defense instruction. Defendant was subsequently found guilty on all counts. The Supreme Court vacated the convictions, holding (1) the circuit court erred in failing to instruct the jury on the castle doctrine; and (2) Defendant was prejudiced by the error. View "State v. Straughter" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court denying Petitioner's petition for a writ of prohibition requesting that the circuit court prohibit Respondent from determining that he must register as a sex offender, holding that Petitioner failed to establish that he was entitled to the writ.Petitioner pleaded guilty to four counts of endangering the welfare of a child. Several months later, Petitioner's probation officer notified him that he was required to register as a sex offender based on allegations in charges that the State later abandoned. Petitioner then filed this petition. The circuit court denied a permanent writ of prohibition. The Supreme Court affirmed, holding (1) the circuit court erred in using the State's abandoned charges to find Petitioner pleaded guilty to sex offenses; but (2) a writ of prohibition was not the proper remedy. View "Doe v. Frisz" on Justia Law

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The Supreme Court vacated the judgment of the circuit court convicting Defendant of fifteen counts of unlawful possession of a firearm following a jury trial, holding that the circuit court committed reversible error by allowing the jury to hear a prejudicial, out-of-court statement made by a witness who never appeared or testified at trial.After Defendant was arrested on allegations of domestic violence against his wife, Beckey, Beckey told officers that Defendant illegally possessed numerous firearms. Defendant was subsequently charged with fifteen counts of unlawfully possessing a firearm. During trial, the out-of-court statement made by Beckey, who did not appear at trial, was elicited during an officer's testimony. The circuit court ruled that Beckey’s statement could be considered as substantive evidence. Defendant was subsequently convicted. The Supreme Court vacated the conviction, holding that the circuit court prejudicially erred in allowing the officer's testimony over Defendant's violation. View "State v. Hollowell" on Justia Law

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The Supreme Court reversed the judgment of the circuit court finding Defendant to be a dangerous offender and remanded the case for resentencing, holding that the State failed to plead all essential facts and introduce evidence establishing sufficient facts to warrant a finding beyond a reasonable doubt that Defendant was a dangerous offender.A jury found Defendant guilty of four counts of second-degree burglary and sentenced him to a total of thirty years' imprisonment. On appeal, Defendant argued that the circuit court committed plain error in finding that he was a dangerous offender. The Supreme Court agreed and reversed Defendant's sentences, holding that the circuit court plainly erred in sentencing Defendant to sentences greater than the maximum authorized by law, resulting in manifest injustice. View "State v. Yount" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court determining that Mo. Rev. Stat. 595.201, as applied to defense attorneys, is constitutionally invalid and that the passage of Senate Bill 569 (SB 569) was procedurally proper, holding that the circuit court did not err in its judgment.Plaintiffs - five public defenders and three criminal defendants - brought this action for declaratory and injunctive relief challenging the constitutional validity of statutes relating to victims of sexual offenses, including SB 569 and section 595.021, which requires criminal defense attorneys to provide information to victims of sexual assault offenses. The circuit court (1) declared section 595.201 constitutionally invalid as as applied to defense counsel because it violated defense attorneys' rights to freedom of speech, and (2) rejected procedural challenges to SB 569 as a whole. The Supreme Court affirmed, holding that the circuit court properly determined that (1) section 595.201.2(4)'s requirements violate defense attorneys' free speech rights, and (2) the General Assembly complied with the procedural limitations imposed by the Missouri Constitution in passing SB 569. View "Fox v. State" on Justia Law

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The Supreme Court reversed the decision of the circuit court sustaining Defendant's motion to dismiss one count of possession of a controlled substance, holding that the circuit court's decision to dismiss the possession count on double jeopardy grounds was erroneous.Defendant was charged with five counts, including the possession count and one count of unlawful use of a weapon by possessing a firearm while in possession of a controlled substance (UUW-possession), all stemming from the same incident. Defendant plead guilty to all counts except the possession count, arguing that because he had been convicted of the greater offense of UUW-possession via his guilty plea, any subsequent prosecution for possession would constitute a double jeopardy violation. The circuit court dismissed the possession count. The Supreme Court reversed, holding that the circuit court erred by dismissing the possession count against Defendant. View "State v. Andrews" on Justia Law

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The Supreme Court denied the writ of prohibition sought by T.J. to dismiss the state's prosecution against him without prejudice so that the circuit court's juvenile division may adjudicate the charges against him, holding that T.J. was not entitled to the writ.The State charged T.J. in the court of general jurisdiction with committing three felony offenses when he was seventeen years old. T.J. filed a motion to dismiss, contending that the juvenile division had the exclusive authority to adjudicate the charges against him pursuant to legislation enacted in 2018. The circuit court overruled the motion. The Supreme Court affirmed, holding that the juvenile division did not have the statutory authority to adjudicate the charged offenses. View "State ex rel. T.J., v. Honorable Cundiff" on Justia Law

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The Supreme Court reversed the judgment of the circuit court dismissing without prejudice the state's prosecution against R.J.G., who was alleged to have committed several felony offenses when he was seventeen years old, holding that the circuit court erred in dismissing the state's prosecution in the court of general jurisdiction.The state charged R.J.G. with felony offenses in a court of general jurisdiction. R.J.G. filed a motion to dismiss on the grounds that the circuit court's juvenile division had the exclusive statutory authority to adjudicate the charges pursuant to legislation enacted in 2018. The circuit court agreed and sustained the motion. The Supreme Court reversed, holding (1) the law as it existed at the time R.J.G. was alleged to have committed the offenses governed which division had the authority to adjudicate the offenses; and (2) the juvenile division did not have the statutory to adjudicate the offenses in this case, and therefore, the circuit court erred in dismissing the state's prosecution in the court of general jurisdiction. View "State v. R.J.G." on Justia Law