Justia Criminal Law Opinion Summaries

The Supreme Court made permanent its preliminary writ of prohibition, holding that the circuit court exceeded its authority in refusing to transfer venue of Defendant’s petition for writ of habeas corpus.While detained in the Jackson County Detention Center, Defendant filed a petition for writ of habeas corpus challenging his judgment of conviction and sentences for first-degree murder. Defendant was later returned to the Crossroads Correctional Center. The Director of the Jackson County Detention Center, who had been named as the respondent in Defendant’s petition, filed a motion to transfer the habeas corpus case to the proper venue in DeKalb County, where Defendant was located, and to substitute the Warden of the Correctional Center as the proper respondent. The Jackson County circuit court overruled the motion. Relator Joshua Hawley then filed a motion to transfer venue to DeKalb County and to substitute the proper respondent. The Jackson County circuit court overruled this motion. Relator sought a writ of prohibition from this Court. The Court granted relief, holding that the Jackson County circuit court exceeded its authority in refusing to transfer venue of Defendant’s petition because the Warden was the proper named respondent and DeKalb County was the proper venue for the habeas petition. View "State ex rel. Hawley v. Honorable Sandra Midkiff" on Justia Law

The Supreme Court affirmed the motion court’s judgment denying Appellant postconviction relief on his twelve claims of ineffective assistance of trial counsel, two claims of ineffective assistance of appellate counsel, and claims challenging the constitutional validity of Mo. Rev. Stat. 562.076 regarding voluntary intoxication and the time limits. Appellant filed his motion under Mo. R. Crim. P. 29.15. In affirming, the Supreme Court held (1) the motion court’s findings of fact and conclusions of law were not clearly erroneous; and (2) the motion court’s judgment regarding an unpreserved claim of error was not plainly erroneous. View "Collings v. State" on Justia Law

The Supreme Court affirmed the motion court’s judgment denying Appellant postconviction relief on his twelve claims of ineffective assistance of trial counsel, two claims of ineffective assistance of appellate counsel, and claims challenging the constitutional validity of Mo. Rev. Stat. 562.076 regarding voluntary intoxication and the time limits. Appellant filed his motion under Mo. R. Crim. P. 29.15. In affirming, the Supreme Court held (1) the motion court’s findings of fact and conclusions of law were not clearly erroneous; and (2) the motion court’s judgment regarding an unpreserved claim of error was not plainly erroneous. View "Collings v. State" on Justia Law

The circuit court did not err in sustaining Defendants’ motions to suppress all evidence seized pursuant to warrant authorizing search of a residence for stolen items.On appeal, the State argued that, while no probable cause existed for a provision of the search warrant form authorizing a search for any deceased human fetus or corpse, the circuit court should have applied the severance doctrine to redact the invalid portion of the warrant and suppress only the evidence seized pursuant to the invalid portion. The Supreme Court disagreed, holding that the circuit court did not err in refusing to apply the severance doctrine and in suppressing all evidence seized because the invalid portions of the search warrant so contaminated the whole warrant that they could not be redacted pursuant to the severance doctrine. View "State v. Gaulter" on Justia Law

The circuit court did not err in sustaining Defendants’ motions to suppress all evidence seized pursuant to warrant authorizing search of a residence for stolen items.On appeal, the State argued that, while no probable cause existed for a provision of the search warrant form authorizing a search for any deceased human fetus or corpse, the circuit court should have applied the severance doctrine to redact the invalid portion of the warrant and suppress only the evidence seized pursuant to the invalid portion. The Supreme Court disagreed, holding that the circuit court did not err in refusing to apply the severance doctrine and in suppressing all evidence seized because the invalid portions of the search warrant so contaminated the whole warrant that they could not be redacted pursuant to the severance doctrine. View "State v. Gaulter" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of two counts of second-degree murder and two counts of armed criminal action. The court held (1) the circuit court did not err in refusing to instruct the jury on self-defense as to felony murder because, for felony murder, Defendant was not prosecuted for his use of force; and (2) as to Defendant’s argument that the circuit court erred in submitting instructions on the felony murder for the second-degree murder counts, Defendant failed to establish plain error and, furthermore, was not prejudiced. View "State v. Oates" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of two counts of second-degree murder and two counts of armed criminal action. The court held (1) the circuit court did not err in refusing to instruct the jury on self-defense as to felony murder because, for felony murder, Defendant was not prosecuted for his use of force; and (2) as to Defendant’s argument that the circuit court erred in submitting instructions on the felony murder for the second-degree murder counts, Defendant failed to establish plain error and, furthermore, was not prejudiced. View "State v. Oates" on Justia Law

The Supreme Court affirmed the judgment of the motion court overruling Appellant’s motion for postconviction relief under Rule 29.15, holding that Appellant’s argument that his appellate counsel was ineffective was unavailing.Appellant was convicted of second-degree murder. On appeal, appellate counsel did not raise as points of error the trial court’s rejections of Appellant’s requested jury instructions. In his Rule 29.15 motion for postconviction relief, Appellant argued that his appellate counsel was ineffective for failing to raise these issues. The motion court denied the motion. The Supreme Court affirmed, holding that appellate counsel’s performance was not constitutionally deficient because appellate counsel did not fail to exercise the customary level of skill and diligence of a reasonably competent attorney. View "Meiners v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of first-degree murder and armed criminal action, holding that the circuit court did not err by refusing to submit a self-defense instruction.In State v. Smith, 456 S.W.3d 849, 852 (Mo. 2015), the Supreme Court reaffirmed that if substantial evidence is presented of the elements of self-defense, the issue is injected and self defense must be submitted by instructing the jury that the State has the burden of proving a lack of self-defense beyond a reasonable doubt. In the instant case, the Supreme Court held that the circuit court did not err in refusing the self-defense instruction because Defendant did not meet his burden of producing evidence sufficient to inject self-defense in his case. View "State v. Bruner" on Justia Law

The Supreme Court reversed the order of the motion court overruling Defendant’s Mo. R. Crim. P. 29.15 motion for postconviction relief alleging that he received ineffective assistance of counsel during his criminal proceedings, holding that counsel failed to timely file an amended motion.Defendant was convicted of first-degree robbery, resisting arrest, and second-degree trafficking. After unsuccessfully pursuing an appeal, Defendant filed a pro se motion for postconviction relief under Rule 29.15. A special public defender entered her appearance on Defendant’s behalf and then filed a motion for leave to file amended answer. The motion court granted the motion. The Supreme Court held that Defendant’s counsel untimely filed the amended motion under Rule 29.15, resulting in a presumption of abandonment. The court remanded the matter for a determination of whether Defendant was abandoned. View "Watson v. State" on Justia Law