Justia Criminal Law Opinion Summaries

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

The Supreme Court made permanent a preliminary writ of mandamus previously issued by this Court directing the circuit court to vacate its order excluding a digital recording from use at trial for various charges relating to the death of Rebecca Ruud's minor daughter, holding that the circuit court erred.A grand jury returned an indictment against Ruud and her then-husband charging them with first-degree murder, felony abuse or neglect of a child resulting in death, and other crimes. The digital recording at issue was between Ruud and her lawyer's staff and yielded incriminating evidence. The circuit court excluded the digital recording from being admitted at trial, concluding that the attorney-client privilege protected the content of the digital recording. The Supreme Court granted the State mandamus relief, holding that the circuit court abused its discretion in finding that the recording was privileged. View "State ex rel. Garrabrant v. Honorable Holden" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree assault of a law enforcement officer, armed criminal action, and unlawful possession of a firearm by a felon, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued that the circuit court erred in overruling with prejudice his motion to dismiss the first-degree assault and armed criminal action counts and retrying him after a mistrial. Defendant's only specific argument was that the circuit court violated the time limitations for his retrial. The Supreme Court affirmed, holding that the circuit court properly followed the procedure approved in State v. Berry, 298 S.W.2d 429 (Mo. 1957), and therefore, Defendant's retrial did not violate Mo. Const. art. I, 19. View "State v. Shegog" on Justia Law

The Supreme Court reversed Defendant's conviction for second-degree felony murder and armed criminal action, holding that the circuit court's evidentiary rulings infringed on Defendant's constitutional right to present a complete defense, as guaranteed by the Sixth and Fourteenth Amendments.Defendant's convictions arose from an alleged robbery during which Defendant shot and killed Mathew Haylock. During trial, Defendant attempted to present evidence that he shot Haylock in self-defense after Haylock attempted to rob him. Each time Defendant raise the issue of presenting his own version of events the circuit court denied him the right to provide such evidence. The Supreme Court reversed and remanded the case, holding that by prohibiting Defendant from presenting evidence about the ultimate issue int his case, the circuit court prevented Defendant from presenting a complete defense, in violation of his constitutional rights. View "Missouri v. Gates" on Justia Law

The Supreme Court affirmed the judgment of the circuit court overruling Defendant's Rule 29.15 motion for postconviction relief without holding an evidentiary hearing, holding that the circuit court did not clearly err in determining that Defendant failed to plead facts not refuted by the record that, if true, resulted in prejudice entitling him to an evidentiary hearing.Defendant was found guilty of four felony sexual offenses. The court of appeals. Defendant subsequently filed a Rule 29.15 motion to vacate, set aside, or correct the judgment, alleging several instances of ineffective assistance of counsel. The circuit court overruled the motion without conducting an evidentiary hearing. The Supreme Court affirmed, holding that the circuit court did not clearly err in denying Defendant's postconviction claims without an evidentiary hearing. View "McLemore v. State" on Justia Law

The Supreme Court affirmed certification order of the family court division releasing and discharging J.T.J. from the jurisdiction of the family court and allowing his case to be transferred to a court of general jurisdiction for trial as an adult, holding that there was no error.A juvenile officer filed a petition in the family court alleging that J.T.J., a juvenile, committed second-degree burglary, first-degree property damages, and misdemeanor stealing. The juvenile officer subsequently filed motions to modify alleging more counts and requesting the transfer of jurisdiction of J.T.J. After a certification hearing, the family court ordered J.T.J. transferred to the court of general jurisdiction. On appeal, J.T.J. argued that the family court erred in entering its certification order because the transfer of jurisdiction of a juvenile is not permitted to allow prosecution under the general law upon the filing of a motion to modify. The Supreme Court affirmed, holding that J.T.J. was not prejudiced, and therefore, relief under plain error review was unavailable. View "In re J.T.J." on Justia Law

The Supreme Court vacated the judgment of the circuit court finding Defendant guilty of voluntary manslaughter and armed criminal action, holding that the circuit court erred in refusing to give a self-defense instruction as requested by Defendant.Defendant was charged with first-degree murder, armed criminal action, and burglary. The jury found Defendant not guilty of burglary but guilty of armed criminal action and the lesser-included crime of voluntary manslaughter. The Supreme Court vacated Defendant's conviction, holding (1) there was substantial evidence to support giving Defendant's proffered self-defense instruction; and (2) the failure to submit this instruction prejudiced Defendant. View "State v. Whitaker" on Justia Law

The Supreme Court reversed the judgment of the circuit court convicting Defendant of two counts of statutory rape in the second degree, holding that the circuit court erred in permitting witness testimony via two-way live video, in violation of Defendant's right to confrontation under the United States and Missouri Constitutions.Defendant was charged in connections of sexual assault by I.S. At trial, the circuit court allowed the virtual testimony of Erik Hall, a crime laboratory employee who collected a buccal swab from Defendant and completed a DNA analysis and laboratory report. Defendant was found guilty of two count of statutory rape. On appeal, Defendant argued that Hall's two-way live video feed testimony violated his constitutional right to confrontation and due process. The Supreme Court reversed, holding that the circuit court erred in admitting Hall's two-way live video testimony, and the error was not harmless beyond a reasonable doubt. View "State v. Smith" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the circuit court dismissing Petitioner's petition for declaratory judgment for failure to state a claim upon which relief can be granted, holding that the circuit court improperly dismissed Petitioner's claim with prejudice.In his petition, Petitioner sought a declaration that his federal supplemental security income was exempt under federal law from paying the required monthly intervention fees to the Missouri Department of Corrections, Division of Probation and Parole, as a condition of his supervised probation. The circuit court dismissed the petition with prejudice. The Supreme Court reversed in part, holding (1) Petitioner's request for declaratory relief was not ripe for adjudication; but (2) because Petitioner may be able to state a claim ripe for adjudication in the future, the circuit court improperly dismissed the claim with prejudice. View "Graves v. Missouri Department of Corrections" on Justia Law

The Supreme Court affirmed the order of the circuit court sustaining Defendant's motion to suppress a cell phone and electronic data stored on that cell phone, holding that the circuit court did not err in sustaining the motion to suppress.The circuit court concluded that the search warrant failed to describe with sufficient particularity the thing to be seized and was so facially deficient that the executing officers could not reasonably have presumed it to be valid. The Supreme Court affirmed, holding (1) the seizure of a cell phone at the sheriff's office was outside the scope of the warrant, so the evidence was not validly seized; and (2) the officer conducting the search did not have a good faith basis when he executed the search warrant at the sheriff's office, contrary to the clear directions of the search warrant to search a cell phone located at a particular address. View "State v. Bales" on Justia Law