Articles Posted in Supreme Court of Missouri

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The Supreme Court affirmed the decision of the circuit court dismissing Mary Doe’s second amended petition seeking to enjoin the enforcement of a portion of the Missouri Informed Consent Law, Mo. Rev. Stat. 188.027 - which she alleged required her to read a booklet, have an ultrasound, and wait seventy-two hours before having an abortion - for failure to state a claim, holding that the circuit court did not err in dismissing the petition. In her petition, Doe claimed that requiring her to read the booklet violated her rights under the Establishment Clause and that reading the booklet and requiring her to have an ultrasound violated her rights under the Missouri Religious Freedom Restoration Act, Mo. Rev. Stat. 1.302.1. The Supreme Court affirmed the denial of Doe’s request for injunctive relief, holding (1) the informed consent law does not adopt any religious tenant but requires those seeking an abortion be offered a booklet that repeats two principles set out in Mo. Rev. Stat. 1.205; (2) the informed consent law does not require a pregnant woman to read the booklet or to have an ultrasound; and (3) Doe did not allege how the seventy-two hour waiting period conflicts with her religion or that it was an undue burden. View "Doe v. Parson" on Justia Law

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The Supreme Court reversed the judgment of the circuit court finding the board of regents of Harris-Stowe State University liable on Dr. Shereen Kader’s claims of national origin discrimination and retaliation under the Missouri Human Rights Act (MHRA), holding that the circuit court’s jury instructions were erroneous and prejudicial. The jury returned a verdict in Dr. Kader’s favor on her claims of national original discrimination and retaliation, awarding $750,000 in actual damages and $1.75 million in punitive damages. The circuit court entered judgment on the jury’s verdict. On appeal, Harris-Stowe argued that the circuit court’s disjunctive jury instructions Nos. 8 and 9 misled and confused the jury, thereby resulting in prejudice. The Supreme Court agreed, holding that the circuit court’s jury instructions were erroneous and prejudicial because they included at least one alternative that did not constitute actionable conduct under the MHRA. View "Kader v. Board of Regents of Harris-Stowe State University" on Justia Law

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The Supreme Court affirmed the circuit court’s decision overruling Defendant’s motion suppress evidence found during a warrantless search and seizure of a bag that the police seized from the back seat of the vehicle in which Defendant had been riding, holding that no prejudice resulted from the suppression motion being overruled. On appeal, Defendant argued that under Arizona v. Gant, 556 U.S. 332 (2009), and State v. Carrawell, 481 S.W.3d 833 (Mo. banc 2016), the evidence should have been suppressed because, contrary to the ruling of the circuit court, the drugs and drug paraphernalia in the bag were not within his possession or control when the bag was seized. The Supreme Court affirmed without reaching the issue of whether Gant or Carrawell required the suppression of the evidence, holding that any error was not prejudicial because other unchallenged evidence fully supported the judgment reached by the circuit court. View "State v. Hughes" on Justia Law

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The Supreme Court affirmed the judgment of the motion court overruling Appellant’s Mo. R. Crim. P. 29.15 motion for postconviction relief after an evidentiary hearing, holding that the motion court did not err. After a jury trial, Appellant was convicted of two counts of first-degree murder. The circuit court adopted the jury’s recommendations and sentenced Appellant to life imprisonment without the possibility of parole for one murder and to death for the other murder. The Supreme Court affirmed the convictions. At issue in this appeal was the motion court’s judgment overruling Appellant’s Rule 29.15 motion after an evidentiary hearing. The Supreme Court affirmed, holding that Appellant was not entitled to postconviction relief for ineffective assistance of counsel because Appellant did not show by a preponderance of the evidence that he was entitled to relief under Strickland v. Washington, 466 U.S. 668 (1984). View "Anderson v. State" on Justia Law

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The Supreme Court affirmed the motion court’s judgment denying Appellant postconviction relief, holding that the motion court’s findings of fact and conclusions of law were not clearly erroneous. On appeal from the motion court’s denial of postconviction relief from his conviction and death sentence for first-degree murder, Appellant claimed that the motion court committed multiple errors. The Supreme Court affirmed the judgment denying postconviction relief, holding (1) the judge did not err in limiting juror questioning; (2) the postconviction process was not tainted by a ruling on the juror issue by a judge who later refused; (3) defense counsel were not ineffective in failing to call additional lay and expert witnesses in the guilt and penalty phase; and (4) Appellant was not entitled to relief on his remaining claims of error. View "McFadden v. State" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court overruling Defendant’s motions to suppress evidence and sentencing Defendant to eight years’ imprisonment in connection with his conviction for possession of a controlled substance. Specifically, the Supreme Court held (1) the circuit court did not err in overruling Defendant’s motions to suppress methamphetamine because Defendant was not unlawfully seized when an officer requested that Defendant produce his driver’s license to verify whether he was driving on a suspended license and Defendant complied with that request; and (2) even though the range of punishment was misstated at the sentencing hearing, Defendant failed to establish that the circuit court imposed sentence based on a mistaken belief. View "State v. Perry" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court overruling Defendant’s motions to suppress evidence and sentencing Defendant to eight years’ imprisonment in connection with his conviction for possession of a controlled substance. Specifically, the Supreme Court held (1) the circuit court did not err in overruling Defendant’s motions to suppress methamphetamine because Defendant was not unlawfully seized when an officer requested that Defendant produce his driver’s license to verify whether he was driving on a suspended license and Defendant complied with that request; and (2) even though the range of punishment was misstated at the sentencing hearing, Defendant failed to establish that the circuit court imposed sentence based on a mistaken belief. View "State v. Perry" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court convicting Defendant of one count of possession of child pornography and sentencing him to fifteen years’ imprisonment. On appeal, Defendant argued (1) the circuit court erred in overruling his motion to suppress evidence because the State failed to prove by a preponderance of the evidence that his consent to the search of his home was voluntary or that exigent circumstances existed warranting officers’ warrantless entry into his home; and (2) he was sentenced based on the circuit court’s “materially false understanding of the possible range of punishment.” The Supreme Court held (1) assuming, without deciding, that Defendant’s consent to the search was not freely and voluntarily given, application of the exclusionary rule was not appropriate because the officers had no knowledge that the search was unconstitutional; and (2) the record did not support a conclusion that the circuit court imposed sentence based on a mistaken belief. View "State v. Pierce" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court convicting Defendant of one count of possession of child pornography and sentencing him to fifteen years’ imprisonment. On appeal, Defendant argued (1) the circuit court erred in overruling his motion to suppress evidence because the State failed to prove by a preponderance of the evidence that his consent to the search of his home was voluntary or that exigent circumstances existed warranting officers’ warrantless entry into his home; and (2) he was sentenced based on the circuit court’s “materially false understanding of the possible range of punishment.” The Supreme Court held (1) assuming, without deciding, that Defendant’s consent to the search was not freely and voluntarily given, application of the exclusionary rule was not appropriate because the officers had no knowledge that the search was unconstitutional; and (2) the record did not support a conclusion that the circuit court imposed sentence based on a mistaken belief. View "State v. Pierce" on Justia Law

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Article I, section 18(c), which voters added to the Missouri Constitution in 2014, does not violate due process. Defendant was convicted of three counts of first-degree statutory sodomy. On appeal, Defendant challenged the constitutionality of article I, section 18(c), arguing that it violates due process because it allows admission of evidence of prior criminal acts in the prosecution’s case-in-chief to prove a defendant has the propensity to commit the charged crime. The Supreme Court held (1) article I, section 18(c) does not violate federal due process on its face; (2) the circuit court is not required to make an express finding of legal relevance before admitting evidence under article I, section 18(c), provided the record reflects a sound basis for the balancing the amendment requires; and (3) the circuit court did not err in admitting evidence of Defendant’s prior criminal act because the danger of unfair prejudice from that evidence did not substantially outweigh its probative value. View "State v. Williams" on Justia Law