Justia Criminal Law Opinion Summaries

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

Seven individuals sought a writ of mandamus or prohibition from the Supreme Court of Missouri, claiming the circuit court failed to hold a preliminary hearing within the required timeframe, thus violating Rule 22.09(a), section 544.270, and section 544.320. The plaintiffs argued that this delay was to allow the circuit attorney additional time to secure an indictment. The primary plaintiff, Lamar Lamont Woods, had been held without bond for 162 days on the complaint, with his preliminary hearing delayed for 129 days beyond the 30-day deadline in Rule 22.09(a).The Supreme Court of Missouri noted that after the filing of a felony complaint, a preliminary hearing should be held within a reasonable time, but no later than 30 days following the defendant's initial appearance if the defendant is in custody, and no later than 60 days if the defendant is not in custody. The Court concluded that Woods was not entitled to a preliminary hearing on his charges, as he had been indicted on the same charges at issue in the complaint filed in June 2023. Since Woods had been indicted, the Court ruled that any relief it might issue in mandamus would not have practical effect on any existing controversy, thus rendering the case moot.The Court also concluded that the "capable of repetition, yet evading review" exception to the mootness doctrine did not apply in this case, as Woods had not established this issue would recur. Consequently, the preliminary writ of mandamus was quashed. View "State ex rel. Woods vs. Dierker" on Justia Law

On March 21, 2019, David Scott Nowicki was discovered unconscious in a vehicle in a ditch off Interstate 70 in Saline County, Missouri. After conducting field sobriety tests, Sergeant Dunfee concluded that Nowicki was impaired and arrested him. Nowicki was later transported to the Saline County jail, where he admitted he had been driving the vehicle but denied using alcohol or drugs in the last 72 hours. A jury trial was scheduled to determine whether Nowicki was guilty of driving while intoxicated. Before the trial, the circuit court was required to determine whether, if the jury found Nowicki guilty, he would be subject to an enhanced sentence due to prior convictions that qualified as intoxication-related traffic offenses (IRTOs). The state argued that Nowicki had four prior convictions that each qualified as an IRTO. As a result, the state contended Nowicki should be sentenced as a chronic offender. The jury found Nowicki guilty and the circuit court sentenced him as a chronic offender to five years in the department of corrections. Nowicki appealed the circuit court's judgment, arguing that the state failed to prove beyond a reasonable doubt that each of his four prior convictions qualifies as an IRTO.The Supreme Court of Missouri held that the state failed to prove beyond a reasonable doubt that each of Nowicki's prior convictions was an intoxication-related traffic offense. The court found that the state's evidence was insufficient to prove beyond a reasonable doubt that the conduct underlying Nowicki's 1986, 1990, and 1994 convictions involved him actually, physically driving a vehicle while intoxicated. Accordingly, the court vacated the circuit court's judgment and remanded the case for resentencing. View "State vs. Nowicki" on Justia Law

The Supreme Court affirmed the judgment of the circuit court overruling Appellant's Mo. R. Crim. P. 24.035 motion for postconviction relief, holding that the circuit court did not clearly err in concluding that counsel was not ineffective for failing to investigate Appellant's competency at his guilty plea and sentencing proceedings.In his Rule 24.035 motion, Appellant, who pleaded guilty to second-degree assault of a special victim and resisting arrest, brought this motion alleging that his attorney was ineffective at both his guilty plea and sentencing proceedings by failing adequately to address his competency to proceed. The circuit court denied relief. The Supreme Court affirmed, holding that the circuit court did not clearly err in concluding that Appellant's attorney was not ineffective for failing to investigate his competency at Appellant's guilty plea and sentencing proceedings. View "Hecker v. State" on Justia Law

The Supreme Court dismissed this appeal brought by the State of an order and judgment dismissing with prejudice criminal charges against Defendant, holding that there was no final, appealable judgment, and therefore, the State lacked statutory authority to appeal pursuant to Mo. Rev. Stat. 547.200.Defendant, who was charged with second-degree murder, first-degree robbery, and armed criminal action, filed a motion to dismiss the indictment. The circuit court sustained the motion in part and dismissed the murder and robbery charges with prejudice, concluding that the Double Jeopardy Clause precluded those charges. The State appealed. The Supreme Court dismissed the appeal, holding that this was an improper appeal. View "State v. Harris" on Justia Law

The Supreme Court granted a writ of prohibition barring the circuit court from taking any further action in Petitioner's criminal case other than dismissing the pending charges against him, holding that the Interstate Agreement on Detainers (IAD) mandated dismissal of Petitioner's case.As a basis for the writ, Petitioner claimed that the circuit court violated the IAD by continuing his criminal case and failing to conduct a trial within 180 days of his request to dispose of his pending charges of rape, sodomy, and sexual abuse. The Supreme Court agreed and granted the writ, holding (1) the IAD applied to the disposition of the state charges pending against Petitioner resulting in a detainer being lodged with the federal penitentiary where he was serving a federal sentence; (2) the State waived any post hoc objection as to the sufficiency of Petitioner's request to dispose of his pending charges; (3) good cause did not exist under the IAD warranting continuing Petitioner's trial; and (4) Petitioner's actions did not waive, toll or otherwise justify extending the timeline mandated by the IAD. View "State ex rel. Wishom v. Honorable Bryant" on Justia Law