Justia Civil Rights Opinion Summaries

After a jury trial, Defendant was convicted of unlawful distribution of a controlled substance to a minor and attempted statutory sodomy in the second degree. The trial court imposed an aggregate sentence of nine years' imprisonment and placed Defendant in the sex offender assessment unit program pursuant to Mo. Rev. Stat. 559.115. The Supreme Court affirmed, holding (1) gaps in the trial transcript did not deny Defendant of meaningful appellate review; (2) the trial court did not abuse its discretion in excluding defense witnesses due to a discovery violation; (3) the trial court did not err in failing to suppress the evidence of marijuana seized from Defendant's home without a warrant because Defendant freely consented to the search of his home; and (4) Defendant's argument that section 559.115 was unconstitutional as applied was without merit. View "State v. Hillman" on Justia Law

After a jury trial, Defendant was convicted of first-degree assault and armed criminal action. The Supreme Court affirmed the trial court's judgment, holding (1) Defendant did not meet his burden of demonstrating that three of the prosecutor's peremptory strikes violated his equal protection rights and right to a fair trial pursuant to Batson v. Kentucky, and thus the trial court did not err in overruling Defendant's Batson challenges to the peremptory strikes; and (2) the trial court did not err in failing to admonish the prosecutor sua sponte or declare a mistrial for alleged prejudicial statements the prosecutor made during closing arguments. View "State v. Carter" on Justia Law

After a trial, Defendant was convicted of one count of attempted use of a child in a sexual performance in violation of Mo. Rev. Stat. 568.080. Defendant appealed, arguing, among other things, that his constitutional right to protected speech was violated because his e-mail exchange with an officer posing as the sixteen-year-old victim did not contemplate or solicit a criminal act. The Supreme Court affirmed the judgment and sentence, holding (1) because Defendant attempted to induce the victim to engage in a sexual performance, Defendant was not punished for fantasy speech, and thus, section 568.080 was not unconstitutional as applied to Defendant; and (2) the evidence was sufficient to support the conviction. View " State v. Blankenship" on Justia Law

After a jury trial, Appellant was convicted of first-degree statutory sodomy. Appellant's conviction was confirmed on appeal. Appellant filed a pro se motion for post-conviction relief, alleging that he received ineffective assistance of counsel and that the prosecutor committed misconduct. The motion court overruled Appellant's post-conviction relief motion without an evidentiary hearing. The Supreme Court affirmed, holding (1) Appellant's motion for post-conviction relief failed to allege facts not refuted conclusively by the record to support his claims for ineffective assistance of counsel; and (2) the motion court did not clearly err in finding that the prosecutor's conduct was appropriate. View "McIntosh v. State" on Justia Law

After a jury trial, Appellant was convicted of burglary in the second degree and stealing. The convictions were affirmed on direct appeal. Appellant subsequently filed a motion for post-conviction relief alleging that trial counsel was ineffective for failing to request a trespassing instruction as a lesser-included offense of burglary. The motion court overruled Appellant's claim without holding an evidentiary hearing. The Supreme Court reversed, holding that the motion court erred in failing to holding evidentiary hearing on Appellant's claims, as Appellant alleged facts, not clearly refuted by the record, showing he was prejudiced by counsel's failure to submit a lesser-included offense instruction. Remanded. View "McNeal v. State" on Justia Law

Appellant, the same-sex partner of a highway patrolman who was killed in the line of duty, applied for survivor benefits under Mo. Rev. Stat. 104.140.3, which provides survivor benefits to the surviving spouse of a highway patrol employee who is killed in the line of duty. The Missouri Department of Transportation and Highway Patrol Employees' Retirement System denied Appellant's application. Appellant argued before the circuit court that the survivor benefits statute violated his equal protection rights by excluding him from survivor benefits because of his sexual orientation and violated the constitutional proscription against special laws. The circuit court affirmed the administrative decision. The Supreme Court affirmed, holding (1) Appellant was not eligible for survivor benefits because he was not married to the patrolman; and (2) the survivor benefits statute is constitutional and is not a special law. View "Glossip v. Mo. Dep't of Transp. & Highway Patrol Employees' Ret. Sys." on Justia Law

In 2001, Respondent pleaded guilty to the class B felony of possession of a controlled substance with intent to distribute. In 2011, Respondent was indicted for knowingly and unlawfully possessing a .38 caliber revolver in violation of Mo. Rev. Stat. 571.070, which provides that a person commits unlawful possession of a firearm if he knowingly has a firearm in his possession and has been convicted of a felony. Respondent moved to quash or dismiss the indictment, arguing that section 571.070 violated the Missouri Constitution as applied to him because it was an ex post facto law. The circuit court entered judgment in favor of Respondent. The Supreme Court reversed, holding that section 471.070 was not an ex post facto law because it did not apply to conduct completed before its enactment. View "State v. Harris" on Justia Law

In 1994, Appellant pleaded guilty to sodomy. Congress subsequently passed the federal sex offender registration act (SORNA), which required individuals such as Appellant to register as sex offenders. Before SORNA was enacted, Appellant completed his involvement in the criminal justice system. Appellant filed a petition challenging SORNA's constitutional validity as applied to him. The circuit court entered summary judgment against Appellant. The Supreme Court affirmed, holding (1) SORNA does not violate the nondelegation doctrine; (2) the registration requirement does not violate Appellant's right to substantive due process nor the prohibition in the U.S. Constitution against ex post facto criminal laws; and (3) SORNA complies with principles of federalism. View "Roe v. Replogle" on Justia Law

Plaintiff, who was formerly employed by Hospital, brought an eight-count petition against Hospital and Doctor (collectively, Defendants) alleging violations of the Missouri Human Rights Act (the MHRA) and other common law claims related to the termination of her employment. The circuit court granted summary judgment in favor of Defendants on all claims. The Supreme Court (1) reversed the circuit court's judgment with respect to Plaintiff's MHRA claims and wrongful discharge claim, holding (i) the circuit court erred in dismissing Plaintiff's MHRA claims on the grounds that Plaintiff failed to satisfy the statutory prerequisites for filing a lawsuit under the MHRA, and (ii) because Plaintiff's amended petition sufficiently invoked the public policy exception to the at-will employment doctrine, the circuit court erred in sustaining summary judgment in Hospital's favor on Plaintiff's wrongful discharge claim; and (2) affirmed the circuit court's judgment as to all remaining counts. Remanded. View "Farrow v. St. Francis Med. Ctr. " on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. After the jury was unable to agree on punishment, the trial court conducted an independent review of the facts pursuant to Mo. Rev. Stat. 565.030.4 and imposed the death sentence. The Supreme Court affirmed the conviction and sentence, holding (1) any errors in the preparation of the trial transcript did not impede adequate appellate review and were not prejudicial; (2) the trial court did not err in its evidentiary rulings or in its instructions to the jury; (3) section 565.030.4 is not unconstitutional; (4) the trial court did not commit plain error in failing to hold a hearing regarding alleged the improper influence of a certain juror during jury deliberations; and (5) the death sentence in this case was proportional to the strength of the evidence. View "State v. Shockley" on Justia Law