Justia Civil Rights Opinion Summaries

After a jury trial, Ines Letica was found guilty of first degree assault and armed criminal action. During voir dire, defense counsel used peremptory challenges to strike four Caucasion females from the panel, to which the State raised a reverse-Batson objection, alleging that a certain venireperson was struck with the peremptory challenge on the basis of gender, race or ethnic origin. The circuit court sustained the objection as to the venireperson. The Supreme Court affirmed the circuit court's judgment, holding (1) the circuit court erred when it ruled prematurely on the reverse-Batson challenge and did not require the State to demonstrate that racial or gender discrimination was the motivating factor for the peremptory strike, but the error was harmless under the facts in this case; (2) the evidence was sufficient to sustain the verdict; (3) Letica's sentences did not constitute plain error; (4) there was no prosecutorial misconduct in this case; and (5) the admission into evidence of certain photographs did not constitute manifest injustice or miscarriage of justice.

This case involved four appeals that were consolidated because each involved the issue of whether evidence obtained in a search of a motor vehicle incident to a traffic arrest was admissible. In each case, there was no reason to believe that evidence of the crime for which each Defendant was arrested was in any of their vehicles. The searches were performed in compliance with binding appellate precedent, but while these cases were pending, Arizona v. Gant was decided, holding that such searches were unlawful. Each defendant, relying on Gant, filed a motion to suppress the evidence obtained from the searches. At issue before the Supreme Court was whether the exclusionary rule suppresses evidence obtained in a search conducted in compliance with binding precedent when such precedent was later overturned. The Supreme Court held (1) in accord with Davis v. U.S., the exclusionary rule did not apply because the searching officers acted in objectively reasonable reliance on settled, binding appellate precedent; and (2) the trial court's judgments sustaining the motions to suppress in three cases were reversed and remanded, and the trial court's judgment in the remaining case overruling the defendant's motion to suppress was affirmed.

Defendant was convicted by a jury of felonious restraint, deviate sexual assault, and first-degree sexual misconduct. Prior to sentencing, Defendant entered into an agreement with the State in which Defendant would plead guilty to two additional criminal counts and waive his rights to a jury trial, to direct appeal, and to seek post-conviction relief. In exchange, the State recommended that Defendant be sentenced to a combined total of fifteen years incarceration on all counts. The circuit court rendered and judgment and sentence in accord with the agreement. Defendant subsequently filed an amended motion for post-conviction relief, alleging ineffective assistance of counsel for, inter alia, incorrectly advising Defendant to waive his rights to a direct appeal. The motion court denied the motion. The Supreme Court vacated the motion court's judgment, holding that Defendant knowingly, voluntarily, and intelligently agreed to waive his post-conviction rights after his trial. Remanded with instructions to dismiss Defendant's post-conviction motion.

Defendant pleaded guilty to two counts of stealing property of a value of more than $500. As part of the plea agreement, Cooper waived his right to file any future motion for post-conviction relief under Mo. R. Crim. P. 24.035 in exchange for the State recommending a fifteen-year sentence on each count to run concurrently with a suspended execution of the sentences and a five-year probationary term. The circuit court rendered judgment and sentences in accord with the plea agreement. After Defendant violated the terms of his probation, his fifteen-year sentences were ordered executed. Defendant subsequently filed a Rule 24.035 motion for post-conviction relief, alleging that defense counsel was ineffective. The motion court overruled the motion on the merits. The Supreme Court vacated the motion court's judgment, holding that Defendant knowingly, voluntarily, and intelligently waived his post-conviction rights. Remanded with instructions to dismiss Defendant's post-conviction motion.

The State filed a felony complaint charging Melvin Davis, a registered sex offender, with violating Mo. Rev. Stat. 566.150 for knowingly being present within 500 feet of a public park that contains playground equipment or a public swimming pool. Davis moved to dismiss the complaint on the ground that section 566.150 was unconstitutional as applied to him because it violated the prohibition against retrospective laws in Mo. Const. art. I, 13. The trial court dismissed the complaint against Davis, holding that because the statute was not enacted until after Davis's original guilty plea, the statute placed a new disability on Davis based on a prior conviction and, therefore, was unconstitutionally retrospective in operation. On appeal, the State argued the constitutional prohibition against retrospective laws in art. I, 13 did not apply to section 566.150 because it was criminal in nature and the prohibition applied only to civil statutes. The Supreme Court affirmed, holding that the State's issue on appeal was not properly preserved for appellate review.

Laclede Gas Company maintained gas lines along Pitman Hill Road in St. Charles County. Pitman Hill Road and the gas lines were located within areas established as public roads on five recorded subdivision plats. Each of the subdivision plats first established public roads and then designated the roads as utility easements. The plats specifically stated that one of the purposes of the utility easements was for the installation and maintenance of gas lines. The County planned to widen Pitman Hill Road, which required Laclede to relocate its gas lines. Laclede declined to pay for the relocation, after which the County filed a declaratory judgment action to require Laclede to bear the cost of relocation. The circuit court entered summary judgment in favor of the County. The Supreme Court reversed, holding that the County was required to reimburse Laclede for displacing the gas lines from Laclede's utility easement because the easements were constitutionally cognizable property interests and, therefore, requiring Laclede to relocate its gas lines without compensation would amount to an unconstitutional taking of private property.

Kasim Faruqi was convicted for attempted enticement of a child. Faruqi appealed, arguing (1) the trial court erred in overruling his motion to dismiss the indictment because the statute setting forth the crime of enticement of a child was unconstitutionally vague, (2) the statements he made to a detective should have been suppressed as involuntary because they were procured by false statements that rose to the level of implied threats, and (3) the evidence discovered on his work computer should have been suppressed because it was discovered as a result of an unlawful search and seizure. The Supreme Court affirmed the judgment of the trial court, holding (1) Faruqi's vagueness challenge failed because the statute puts a person of ordinary intelligence on notice that, if he or she is at least twenty-one years old, attempting to entice a person younger than the age of fifteen years for the purpose of engaging in sexual conduct, regardless of whether the victim is, in fact, younger than fifteen years, is a crime; (2) Faruqi's statements were not obtained involuntarily; and (3) Faruqi's Fourth Amendment claim was barred as he maintained no subjective expectation of privacy in his work computer.

After a jury trial, Reginald Griffin was found guilty of murder for the fatal stabbing of James Bausley and sentenced to life imprisonment without parole. Griffin filed a petition for a writ of habeas corpus, alleging that the State failed to disclose evidence that implicated another man as an alternate perpetrator and, hence, the State violated Brady v. Maryland. The circuit court denied the habeas petition. The Supreme Court granted the petition and held that Griffin met his burden of proving entitlement to habeas relief. Because Griffin showed that the nondisclosure of the evidence at issue was prejudicial for Brady purposes, he also established the prejudice necessary to overcome the procedural bar to granting him habeas relief. Accordingly, Griffin's conviction for the murder of Bausley was vacated.