Justia Criminal Law Opinion Summaries

Respondent was arrested for driving while intoxicated and agreed to take a breath test on a breath analyzer, which measured a .172-percent blood alcohol concentration (BAC). The Director of Revenue revoked Respondent’s driving privileges based on the results of the breath test. Respondent timely filed a petition for a trial de novo, arguing that her breath test results were invalid because the breath analyzer used in her case was calibrated using only one solution. The trial court agreed with Respondent and excluded the breath test results. As a result, the court concluded that the Director failed to meet the State’s burden of providing sufficient credible evidence that Respondent drove with a BAC above .08 percent. The Supreme Court affirmed, holding that the trial court (1) correctly applied the regulation in place at the time of the breath test; and (2) correctly concluded that the Director failed to lay a proper foundation for the admission of the results of Respondent’s breath test. View "Stiers v. Dir. of Revenue" on Justia Law

A police officer searched a plastic grocery bag that Defendant was holding after he was already handcuffed and seated in the police car. Inside the bag the officer discovered heroin. Defendant was charged with the class C felony of drug possession. Defendant filed a motion to suppress evidence of the heroin, arguing that neither the arrest nor the search of his plastic bag was lawful. The circuit court overruled the motion, and Defendant was convicted. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in overruling Defendant’s motion to suppress evidence of the heroin because (1) the arrest of Defendant was lawful; and (2) the search of Defendant’s bag was not a lawful search incident to arrest, but the exclusionary rule did not apply to this case. View "State v. Carrawell" on Justia Law

Petitioner was convicted of two counts of first-degree murder for the murders to two sisters. Petitioner was sentenced to death for the murders. Petitioner filed a petition for a writ of habeas corpus in the Supreme Court, claiming that newly discovered evidence showed that the State violated Brady v. Maryland by withholding material evidence and that the Brady violation was prejudicial. The Supreme Court appointed a special master to take evidence and issue findings of fact and conclusions of law as to Petitioner’s allegation. The master eventually issued a report finding that the State had violated Brady by failing to produce evidence favorable to Petitioner and that the State’s failure to disclose this evidence was prejudicial to Petitioner. The Supreme Court adopted the master’s recommendation and vacated Petitioner’s convictions and sentences for first-degree murder, holding that substantial evidence supported the master’s findings that the State deliberately violated Brady and that the suppressed evidence, along with the totality of other evidence, showed cause and prejudice sufficient to undermine confidence in the outcome of the trial. View "State ex rel. Clemons v. Larkins" on Justia Law

Father was charged with criminal nonsupport in violation of Mo. Rev. Stat. 568.040. Father filed a motion to dismiss the information and to declare section 568.040.1 unconstitutional as a violation of his due process rights under the United States and Missouri constitutions. The trial court granted the motion and dismissed the information, concluding that the 2011 amendment to the statute, which removed the phrase “without good cause” as an element of the offense, and instead expressed it as an affirmative defense, impermissibly shifted the burden of proof to the defendant on an element of the crime. The Supreme Court reversed, holding that the statute is constitutional because due process allows a defendant to bear the burden of pleading and proving the affirmative defense of inability to provide support for good cause. View "State v. Meacham" on Justia Law