Justia Civil Rights Opinion Summaries

Articles Posted in Supreme Court of Missouri
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The Supreme Court affirmed the judgment of the circuit court convicting Defendant of three counts of first-degree statutory sodomy and three counts of incest and sentencing him to a total of eighty-seven years' imprisonment, holding that there was no error.On appeal, Defendant argued that the circuit court erred in admitting evidence pursuant to Mo. Const. art. I, 18(c), overruling objections to the State's closing argument, admitting expert testimony and particular exhibits, and finding sufficient evidence to support the convictions. The Supreme Court affirmed, holding that there was no error, plain or otherwise, or abuse of discretion in the proceedings below. View "State v. Minor" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court convicting Defendant of tampering with a judicial officer and second-degree harassment of his probation officer, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) Defendant's facial overbreadth challenge to the second-degree harassment statute, Mo. Rev. Stat. 565.091, was without merit; (2) there was sufficient evidence to support Defendant's conviction for second-degree harassment; and (3) the district court did not violate Defendant's right to be free from double jeopardy when it sentenced Defendant for both tampering with a judicial officer and second-degree harassment. View "State v. Collins" on Justia Law

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The Supreme Court vacated the judgment of the circuit court convicting Defendant of fifteen counts of unlawful possession of a firearm following a jury trial, holding that the circuit court committed reversible error by allowing the jury to hear a prejudicial, out-of-court statement made by a witness who never appeared or testified at trial.After Defendant was arrested on allegations of domestic violence against his wife, Beckey, Beckey told officers that Defendant illegally possessed numerous firearms. Defendant was subsequently charged with fifteen counts of unlawfully possessing a firearm. During trial, the out-of-court statement made by Beckey, who did not appear at trial, was elicited during an officer's testimony. The circuit court ruled that Beckey’s statement could be considered as substantive evidence. Defendant was subsequently convicted. The Supreme Court vacated the conviction, holding that the circuit court prejudicially erred in allowing the officer's testimony over Defendant's violation. View "State v. Hollowell" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court reducing the jury's punitive damages award against HALO Branded Solutions, Inc., holding that the circuit court's application of the punitive damages cap in Mo. Rev. Stat. 510.265 did not violate All Star Awards & Ad Specialities Inc.'s right to a jury trial, and the reduced award did not violate HALO's due process rights.All Star brought this action against HALO and All Star's employee, Doug Ford. A jury found HALO tortiously interfered with All Star's business expectancy, that Ford breached his duty of loyalty to All Star, and that HALO conspired with Ford to breach this duty of loyalty. The jury awarded All Star $525,542 in actual damages and assessed $5.5 million in punitive damages against HALO. The circuit court applied section 510.265 and capped the punitive damages award at five times All Star's actual damages - or $2,627,709 - and entered final judgment in accordance with the jury's verdicts. The Supreme Court affirmed, holding (1) the circuit court properly reduced All Star's award of punitive damages; and (2) the reduced award was within the constitutional parameters of due process. View "All Star Awards & Ad Specialties, Inc. v. HALO Branded Solutions, Inc." on Justia Law

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The Supreme Court vacated the order of the circuit court entering a declaratory judgment that Mo. Rev. Stat. 115.646 violated public officials' right to free speech and was void for vagueness, holding that the circuit court erred.Section 115.646 prohibits officials from directly using public funds to advocate, support, or oppose a ballot measure or candidate for public office. Plaintiffs initiated a lawsuit seeking a judgment declaring section 115.646 unconstitutional. The circuit court sustained Plaintiffs' motion for summary judgment, declaring that section 115.646 violated the officials' First Amendment rights. The Supreme Court vacated the judgment, holding (1) because section 115.646 regulates the use of public funds, not the officials' speech, it does not implicate the free speech clause of the First Amendment; and (2) the circuit court erred in declaring certain words and phrases in the statute to be unconstitutionally vague. View "City of Maryland Heights v. State" on Justia Law

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The Supreme Court reversed Defendant's conviction for second-degree felony murder and armed criminal action, holding that the circuit court's evidentiary rulings infringed on Defendant's constitutional right to present a complete defense, as guaranteed by the Sixth and Fourteenth Amendments.Defendant's convictions arose from an alleged robbery during which Defendant shot and killed Mathew Haylock. During trial, Defendant attempted to present evidence that he shot Haylock in self-defense after Haylock attempted to rob him. Each time Defendant raise the issue of presenting his own version of events the circuit court denied him the right to provide such evidence. The Supreme Court reversed and remanded the case, holding that by prohibiting Defendant from presenting evidence about the ultimate issue int his case, the circuit court prevented Defendant from presenting a complete defense, in violation of his constitutional rights. View "Missouri v. Gates" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court overruling Defendant's Rule 29.15 motion for postconviction relief without holding an evidentiary hearing, holding that the circuit court did not clearly err in determining that Defendant failed to plead facts not refuted by the record that, if true, resulted in prejudice entitling him to an evidentiary hearing.Defendant was found guilty of four felony sexual offenses. The court of appeals. Defendant subsequently filed a Rule 29.15 motion to vacate, set aside, or correct the judgment, alleging several instances of ineffective assistance of counsel. The circuit court overruled the motion without conducting an evidentiary hearing. The Supreme Court affirmed, holding that the circuit court did not clearly err in denying Defendant's postconviction claims without an evidentiary hearing. View "McLemore v. State" on Justia Law

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The Supreme Court reversed the judgment of the circuit court convicting Defendant of two counts of statutory rape in the second degree, holding that the circuit court erred in permitting witness testimony via two-way live video, in violation of Defendant's right to confrontation under the United States and Missouri Constitutions.Defendant was charged in connections of sexual assault by I.S. At trial, the circuit court allowed the virtual testimony of Erik Hall, a crime laboratory employee who collected a buccal swab from Defendant and completed a DNA analysis and laboratory report. Defendant was found guilty of two count of statutory rape. On appeal, Defendant argued that Hall's two-way live video feed testimony violated his constitutional right to confrontation and due process. The Supreme Court reversed, holding that the circuit court erred in admitting Hall's two-way live video testimony, and the error was not harmless beyond a reasonable doubt. View "State v. Smith" on Justia Law

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The Supreme Court vacated the judgment of the circuit court finding that Juvenile committed acts that would constituted first-degree statutory sodomy if committed by an adult, holding that the circuit court erroneously declared and applied the law in admitting two-way video testimony, in violation of Juvenile's right to confrontation.Prior to his adjudication hearing, Juvenile filed an objection to a virtual adjudication and request to appear in person, arguing that he had a constitutional and statutory right to face-to-face confrontation of witnesses against him. The objection was overruled, and the court held the hearing in a "hybrid" format that utilized videoconferencing technology due to the COVID-19 pandemic. After the hearing, the circuit court sustained the allegation of first-degree statutory sodomy beyond a reasonable doubt. The Supreme Court vacated the judgment, holding that the circuit court's general statements concerning COVID-19 did not satisfy the requisite standard for admitting two-way video testimony, in violation of Juvenile's confrontation rights. View "In re C.A.R.A." on Justia Law

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The Supreme Court affirmed the order of the circuit court sustaining Defendant's motion to suppress a cell phone and electronic data stored on that cell phone, holding that the circuit court did not err in sustaining the motion to suppress.The circuit court concluded that the search warrant failed to describe with sufficient particularity the thing to be seized and was so facially deficient that the executing officers could not reasonably have presumed it to be valid. The Supreme Court affirmed, holding (1) the seizure of a cell phone at the sheriff's office was outside the scope of the warrant, so the evidence was not validly seized; and (2) the officer conducting the search did not have a good faith basis when he executed the search warrant at the sheriff's office, contrary to the clear directions of the search warrant to search a cell phone located at a particular address. View "State v. Bales" on Justia Law