Justia Criminal Law Opinion Summaries

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

The Supreme Court denied Defendant's petition for a writ of habeas corpus, holding that Defendant was eligible for the death penalty because he failed to prove that he was intellectually disabled, and Defendant was not entitled to relief on any of his remaining claims.Defendant was found guilty of three counts of first-degree murder and sentenced to three death sentences. After the Supreme Court issued an order setting Defendant's execution date Defendant filed this petition for writ of habeas corpus, raising three allegations. The Supreme Court affirmed, holding (1) Defendant was not intellectually disabled and was therefore eligible for the death penalty; (2) the jury instructions on intellectual disability did not violate Defendant's constitutional rights; and (3) Defendant's method of execution claim failed. View "State ex rel. Johnson v. Blair" on Justia Law

The Supreme Court affirmed the judgment of the motion court overruling Appellant's Rule 24.035 amended motion seeking to set aside his guilty plea and vacate his judgment and sentence, holding that the motion court's findings of fact and conclusions of law were not clearly erroneous.Appellant pleaded guilty to first-degree involuntary manslaughter and armed criminal action and was sentenced to two consecutive terms of fifteen and twenty-five years' imprisonment. Appellant later filed a pro se Rule 24.035 to vacate, set aside, or correct the judgment and sentence. The motion court granted the motion, set aside Appellant's guilty plea, and reinstated his original charges. Thereafter, Appellant pled guilty to second-degree murder and armed criminal action and was sentenced to concurrent terms of life and thirty years' imprisonment. Appellant then filed a second Rule 24.035 motion. The motion court overruled the motion. The Supreme Court affirmed, holding that the motion court did not err. View "Staten v. State" on Justia Law

The Supreme Court reversed the judgment of the postconviction relief court overruling Appellant's Rule 24.035 motion for postconviction relief, holding that the mistaken belief held by Defendant regarding his sentencing, which arose from his plea counsel's direct assurance, resulted in his plea of guilty.After Defendant pleaded guilty to driving while intoxicated plea counsel advised him he would be eligible for long-term treatment under Mo. Rev. Stat. 217.362. The circuit court sentenced Defendant pursuant to that provision, but after sentencing, Defendant discovered he was statutorily ineligible for placement in the program. Defendant filed a motion to vacate, set aside or correct his judgment or sentence, arguing that his guilty plea was involuntary unknowing, and unintelligent. The postconviction relief court overruled the motion. The Supreme Court reversed, holding that prejudice existed and, therefore, the judgment overruling Defendant's motion was clearly erroneous. View "Hefley v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court overruling Defendant's Rule 29.15 motion for postconviction relief, holding that the circuit court's findings of fact and conclusions of law were not clearly erroneous.Defendant was convicted of two counts of first-degree murder, five counts of armed criminal action, and one count each of first-degree burglary, forcible rape, and forcible sodomy. Defendant was sentenced to death for each murder count. In his postconviction motion, Defendant argue that the State committed multiple Brady violations and that trial counsel provided ineffective assistance. The Supreme Court affirmed, holding that the circuit court's findings of fact and conclusions of law were not clearly erroneous. View "Driskill v. State" on Justia Law