Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court finding Defendant guilty of residing within 1,000 feet of George Washington Carver Middle School, holding that the circuit court did not err in concluding that Defendant was within 1,000 feet of the Carver Middle School property line.On appeal, Defendant argued that the circuit court erred in concluding that the word "school" as used in Mo. Rev. Stat. 566.147, includes the Carver Middle School building as well as the adjoining school property. The Supreme Court affirmed, holding that there was sufficient evidence supporting Defendant's conviction for residing within 1,000 feet of the Carver Middle School property line. View "State v. McCord" on Justia Law

The Supreme Court reversed Defendant's conviction for the class E felony of loitering within 500 feet of a public park, in violation of Mo. Rev. Stat. 566.150, holding that there was insufficient evidence to support the conviction.On appeal, Defendant argued (1) the evidence was insufficient to support the conviction because it failed to show that he was knowingly within 500 feet of a public park or that he was loitering, and (2) section 556.150 is constitutionally invalid because it is vague and overbroad. The Supreme Court agreed with Defendant's first argument, holding that the State failed to introduce evidence from which a fact-finder reasonably could conclude that Defendant was within 500 feet of a public park. View "State v. Lehman" on Justia Law

The Supreme Court dismissed the appeal of the dismissal of a motion for a new trial filed decades after a criminal conviction became final, holding that Appellant was dismissing an order dismissing a motion the circuit court had no authority to sustain.In 1995, Appellant was convicted of murder. In 2019, City of St. Louis Circuit Attorney Kimberly Gardner filed a motion for new trial claiming that there was newly discovered evidence showing Appellant's innocence. The court then concluded that it lacked authority to entertain the motion because the State was not permitted to file the motion and because it was untimely. The Supreme Court affirmed, holding that there was no statutory authority for the right to appeal in this case. View "State v. Johnson" on Justia Law

The Supreme Court affirmed the judgment of the circuit court against Jessica Hicklin in a declaratory judgment action against Eric Schmitt, Missouri's attorney general and other State parties, holding that Hicklin's claims were without merit.Hicklin asserted in her complaint that her 1997 life-without-parole sentence for first-degree murder was invalid following the United States Supreme Court's decisions in Miller v. Alabama, 567 U.S. 460 (2012), and Montgomery v. Louisiana, 136 S. Ct. 718 (2016). The Supreme Court disagreed, holding (1) challenges to the constitutional validity of Missouri statutes are properly brought in a declaratory judgment action; (2) Missouri's General Assembly can accept the Supreme Court's invitation to remedy Miller-affected sentences by supplying parole eligibility; and (3) the Parole Board's authority does not violate the separation of powers. View "Hicklin v. Schmitt" on Justia Law

The Supreme Court made permanent its preliminary writ of prohibition prohibiting the circuit court from enforcing an order requiring Franklin County Prosecuting Attorney Matthew Becker and an associate prosecuting attorney, Matthew Houston, to appear and provide sworn testimony under oath at a pretrial motion hearing, holding that this case did not merit a presumption of vindictiveness.Defendant was indicted on two counts of first-degree murder and two counts of armed criminal action. After the State filed a notice of intent to seek the death penalty Defendant filed a motion to strike, alleging prosecutorial vindictiveness. The circuit court entered an order requiring Becker and Houston to appear and provide sworn testimony regarding Defendant's motion to strike. Becker filed a petition for a writ of prohibition seeking to prevent the circuit court from ordering him and Houston to provide sworn testimony. The Supreme Court issued a preliminary writ of prohibition. The Court then made permanent its writ of prohibition, holding (1) Defendant failed to allege sufficient facts to support a presumption of prosecutorial vindictiveness; and (2) the circuit court's order would cause irreparable harm by requiring Becker and Houston to divulge privileged work product. View "State ex rel. Becker v. Honorable Gael D. Wood" on Justia Law

The Supreme Court reversed Defendant's conviction of felony stealing, holding that because Defendant's conviction for felony stealing was not final when State v. Bazell, 497 S.W.3d 263 (Mo. banc 2016), was decided, Defendant was entitled to the benefit of its ruling at the time of his sentence.Defendant pled guilty to appropriating batteries and a battery charger worth at least $500. Imposition of sentence was suspended, and Defendant was placed on probation for five years. While Defendant was on probation, the Court decided Bazell. Thereafter, the circuit court revoked Defendant's probation and sentenced him to four years in prison. On appeal, Defendant argued that his offense constituted a misdemeanor pursuant to Bazell and he should be sentenced accordingly. The Supreme Court agreed, holding that the circuit court erred in overruling Defendant's objection and sentencing him for a class C felony when, under the Court's holding in Bazell, his offense was a class A misdemeanor. View "State v. Golden" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree attempted rape and other offenses, holding that the circuit court committed no error regarding the claims Defendant asserted on appeal.After a jury trial, Defendant was convicted of first-degree attempted rape, second-degree domestic assault, first-degree domestic assault, armed criminal action, and victim tampering. On appeal, Defendant raised five points challenging the circuit court's rulings admitting or excluding certain evidence. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion or plainly err in excluding the challenged evidence View "State v. Loper" on Justia Law

The Supreme Court vacated the judgment of the circuit court convicting Defendant of one count of robbery in the first degree, holding that the circuit court erred in excluding expert witness testimony regarding various factors that can impact the reliability of eyewitness identification.The case against Defendant was largely based on the identification provided by the victim at a "show up" that occurred minutes after the crime occurred. After the state rested its case, Defendant's counsel sought to have an expert witness testify about he factors that can impact the reliability of eyewitness identifications generally. The trial court excluded the expert testimony. On appeal, arguing that the circuit court erred in excluding the testimony. The Supreme Court agreed, holding (1) the exclusion of the expert testimony deprived Defendant of his opportunity to present expert evidence about the most important issue the jury had to decide - whether the victim's identification of Defendant was mistaken; and (2) the likelihood that the expert testimony would have altered the outcome was too high to affirm Defendant's conviction. View "State v. Carpenter" on Justia Law

The Supreme Court affirmed the order of the circuit court entering partial summary judgment in favor of Plaintiff on the issue of liability, holding that the circuit court did not err in entering summary judgment on the issue of liability in Plaintiff's favor.After he mobile home caught on fire Plaintiff sued several defendants, including Mehrdad Fotoohighiam, alleging that Fotoohighiam and the other defendants conspired to set her home on fire, causing her mental and physical harm and property damage. The circuit court entered partial summary judgment as to liability in Plaintiff's favor. After a jury trial on the issue of damages only the jury returned a verdict of $250,000 in actual damages and $2,500,000 in punitive damages. The Supreme Court affirmed, holding that the circuit court correctly determined that the uncontroverted material facts established Plaintiff's right to partial summary judgment on the issue of liability. View "Green v. Fotoohighiam" on Justia Law

The Supreme Court reversed the judgment of the circuit court against Defendant for one count of class C felony stealing and two counts of class A misdemeanor stealing, holding that absent proof of value, the offense submitted was a class D misdemeanor, not a class A misdemeanor, and that the circuit court should have entered judgment against Defendant for a class D felony rather than a class C felony.The jury instructions in this case required the jury to find Defendant retained the two victims' personal items without their consent and with the purpose of withholding this property from them. At trial, the State did not present evidence of the value of the stolen items of personal property. At issue on appeal was whether the circuit court properly entered judgment for one count of class C felony and two counts of class A misdemeanor stealing. The Supreme Court remanded the case, holding that the circuit court should have entered judgment for one count of class D felony stealing and two counts of class D misdemeanor stealing. View "State v. Knox" on Justia Law