Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court judgment overruling Defendant's Mo. Rev. Stat. 29.15 motion for postconviction relief from his death sentence for first degree murder, holding that the circuit court's findings of fact and conclusions of law were not clearly erroneous.On appeal, Defendant argued that the circuit court committed multiple errors affecting the guilt phase, penalty phase, and postconviction relief phases of his criminal case. Among other things, Defendant argued that the circuit court erred in failing to find that his counsel provided ineffective assistance in several respects. The Supreme Court affirmed, holding that the circuit court's findings of fact and conclusions of law were not clearly erroneous and that the circuit court did not err in denying postconviction relief. View "McFadden v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court committing Appellant to the department of mental health (DMH) as a sexually violent predator (SVP), holding that the circuit court did not err.In 2005, Appellant pleaded guilty to felony sex abuse. Before his release in 2016, the State filed a petition seeking to civilly commit him as an SVP. A jury found Appellant to be an SVP and the circuit court committed him to DMH. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion when it prohibited Appellant from questioning the jury panel about the specific ages of child victims; (2) the circuit court did not err when it excluded a portion of the testimony regarding Appellant's risk of future dangerousness; (3) the circuit court did not plainly err in submitting Instruction No. 6, the verdict director; (4) Appellant received effective assistance of counsel at his probable cause hearing; (5) the circuit court did not plainly err in overruling Appellant's motion for new trial based on juror nondisclosure of bias; (6) Appellant's claim of ineffective assistance of counsel for failure to move for change of venue was without merit; and (7) omissions in the trial transcript did not prejudice Appellant's appellate review. View "In re Care & Treatment of D.N." on Justia Law

The Supreme Court affirmed the judgment of the circuit court sentencing Defendant to two terms of life imprisonment without the possibility of parole, holding that Mo. Rev. Stat. 565.020 is constitutional as applied to Defendant.Defendant was nineteen years old when he killed his grandparents. Defendant was convicted of two counts of first-degree murder and sentenced to death for each murder count. Later, a federal district court ordered the state of Missouri either to sentence Defendant to life without the possibility of probation or parole or grant him a new penalty phase trial. On remand, Defendant argued that section 565.020, which then provided that first-degree murder shall be punishable either by death or imprisonment for life without eligibility for probation or parole, was unconstitutional as applied to him because offenders who commit crimes at nineteen years old also display the transient, hallmark features of adolescence affecting risk and impulse control. The circuit court rejected Defendant's claims and sentenced him to life without the possibility of parole on both murder counts. The Supreme Court affirmed, holding that where Supreme Court precedent clearly defines a juvenile as an individual younger that eighteen years of age for purposes of the considerations Defendant sought, section 565.020 was constitutional as applied to Defendant. View "State v. Barnett" on Justia Law

The Supreme Court dismissed Appellant's appeal challenging his convictions for first-degree statutory sodomy and attempted first-degree statutory sodomy, holding that, because two counts as to which the jury could not reach of verdict remained pending, the circuit court's judgment was not final.A jury convicted Appellant of the two sodomy charges but could not reach a verdict on the charges for first-degree statutory rape and incest. The circuit court declared a mistrial as to the rape and incest charges. The court then entered a judgment disposing of and imposing sentences on the two sodomy charges. The judgment, however, was silent as to the two counts on which the court had ordered a mistrial. Appellant appealed. The Supreme Court dismissed the appeal, holding that because Appellant was charged with four counts and two of those counts remained pending before the circuit court, the court's judgment of conviction on only two of the counts was not final for purposes of appeal. View "State v. Waters" on Justia Law

The Supreme Court affirmed the judgment of the circuit court sustaining the chairman of the Missouri board of probation and parole's motion to dismiss Appellant's petition for declaratory judgment in which he sought a declaration of his right to a parole hearing, holding that the repeal of Mo. Rev. Stat. 195.295.3 did not render Appellant parole eligible.In 2013, a jury found Appellant guilty of drug trafficking in the second degree for acts committed in 2009. Defendant was sentenced under section 195.295.3 as a prior drug offender to a term of imprisonment without eligibility for parole. After the general assembly repealed section 195.295 in January 2017, Appellant filed his petition for declaratory judgment arguing he was eligible for parole because the statute that had rendered him parole ineligible had been repealed. The circuit court dismissed the petition, concluding that the repeal of the statute could not be applied retroactively because it would alter Appellant's sentence. The Supreme Court affirmed, holding that because Appellant's parole ineligibility was part of his sentence, the repeal of section 195.295.3 did not render him eligible for parole. View "Mitchell v. Phillips" on Justia Law

The Supreme Court reversed the judgment of the circuit court sustaining Respondent's motion for judgment on the pleadings and granting Respondent a hearing on his single-count petition for declaratory judgment claiming his parole eligibility should no longer be governed by Mo. Rev. Stat. 195.295 and releasing Respondent on parole, holding that the repeal of section 195.295 had no effect on Respondent's parole eligibility.Respondent was found guilty of trafficking drugs in the second degree for acts committed in May 2006. Respondent was sentenced as a prior drug offender to twenty-five years' imprisonment without eligibility for parole under section 195.295. On January 1, 2017, section 195.295 was repealed. At issue was the legal effect section 195.295's repeal had on Respondent's eligibility for parole. The Supreme Court held that, for the reasons set forth in Mitchell v. Jones, __ S.W.3d __, also decided today, Respondent was not eligible for parole. View "Woods v. Missouri Department of Corrections" on Justia Law

The Supreme Court vacated Defendant's guilty by mental disease or defect (NGRI) plea that the circuit court accepted after finding Defendant lacked competence to continue with the criminal proceedings, holding that the circuit court exceeded its authority under Mo. Rev. Stat. 552.020.8 and violated Defendant's due process rights.Defendant was charged with first-degree robbery and armed criminal action. After accepting Defendant's NGRI plea the circuit court found Defendant lacked competence to proceed and committed him to the department of mental health. The Defendant sought a writ of habeas corpus arguing that, pursuant to section 552.020.8, upon finding him incompetent, the circuit court was required to suspend the proceedings and commit him to the department of mental health. The Supreme Court agreed, holding that, by accepting Defendant's NGRI plea despite finding him incompetent to proceed, the circuit court exceeded its authority pursuant to section 552.020.8 and violated Defendant's due process rights. View "State ex rel. Kelly v. Inman" on Justia Law

The Supreme Court affirmed Defendant's conviction of felony possession of a controlled substance, holding that the circuit court did not err in admitting evidence obtained from Defendant's statements and a search of his vehicle after a traffic stop.On appeal, Defendant argued that the circuit court erred in overruling his motion to suppress because the traffic stop was unreasonable and violated the Fourth Amendment. The Supreme Court affirmed, holding (1) crossing the fog line and driving on the shoulder is a traffic violation and creates a lawful justification for a traffic stop; and (2) the stop in this case was justified after Defendant's vehicle crossed the fog line and drove on the shoulder and therefore did not constitute an unreasonable seizure under the Fourth Amendment. View "State v. Smith" on Justia Law

The Supreme Court affirmed the judgment of the motion court denying Defendant's motion for postconviction relief filed under Mo. R. Crim. P. 29.15, holding that the motion court did not err in denying postconviction relief.Defendant was convicted of murder in the first degree, armed criminal action, burglary in the first degree, and unlawful possession of a firearm by a felon. The trial court sentenced Defendant to death. Defendant later moved for postconviction relief, alleging ineffective assistance of counsel. The motion court denied the postconviction motion. The Supreme Court affirmed, holding that the motion court did not err in denying Defendant's claims. View "Hosier v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of one count of first-degree assault and one count of felony resisting arrest, holding that sufficient evidence supported a finding that Defendant resisted an arrest for an offense and that offense constituted a felony as a matter of law.At the close of the State's evidence Defendant moved for judgment of acquittal. The circuit court overruled the motion as to the counts at issue on this appeal. Defendant appealed, arguing that the circuit court erred in overruling his motion for judgment of acquittal on the felony resisting arrest count because there was insufficient evidence presented to support a finding of guilt. The Supreme Court affirmed, holding that the evidence was sufficient to support Defendant's conviction of felony resisting arrest. View "State v. Shaw" on Justia Law