Justia Constitutional Law Opinion Summaries

After a jury trial, Defendant was found guilty of first-degree murder, first-degree robbery, and two counts of armed criminal action for shooting a killing a victim during the second of two robberies he committed when he was seventeen years old. The trial court sentenced Defendant to life in prison without the possibility of parole for murder. The Supreme Court affirmed, holding (1) the trial court did not reversibly err in playing Defendant's videotaped interrogation at trial; and (2) Defendant's sentence of life without parole violated the Eighth Amendment because it was imposed without any opportunity for the sentencing court to consider whether this punishment was appropriate in light of Defendant's age, maturity, and other factors discussed in Miller v. Alabama. Remanded. View "State v. Hart" on Justia Law

After a jury trial, Defendant was convicted of involuntary manslaughter in the first degree and armed criminal action. Defendant subsequently filed a petition for a writ of habeas corpus, claiming that the trial court's practice of permitting qualified jurors to opt out of jury service by agreeing to perform community service constituted a fundamental and systemic failure to comply with the statutory jury selection requirements. The circuit court and court of appeals denied the motion. Defendant then filed his writ petition with the Supreme Court. The Supreme Court denied the petition, holding that allowing five prospective jurors to opt out of service during Defendant's trial did not constitute a "substantial failure" to comply with the jury selection statutes or undermine the confidence in the verdict. View "State ex rel. Sitton v. Norman" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to death. Defendant subsequently filed a motion for post-conviction relief. The motion court denied the motion after an evidentiary hearing on five of Defendant's fourteen allegations of error. The supreme Court affirmed, holding, among other things, that the motion court did not clearly err in (1) denying Defendant's claim that his trial counsel were ineffective for failing to investigate and present a diminished capacity defense; (2) failing to find the State committed a Brady violation; and (3) failing to find Defendant's trial counsel were ineffective for failing to object to the admission of a reenactment video without an evidentiary hearing. View "Johnson v. State" on Justia Law

The marriage of Husband and Wife was dissolved in 2003. In 2005 and 2006, the trial court reduced Husband's child support obligations and made no change to his maintenance obligation. While Husband's second appeal was pending, Wife filed a motion for attorney's fees on appeal. The trial court ordered Husband to pay $7,500 of Wife's attorney fees on appeal. The Supreme Court affirmed, holding (1) Mo. Rev. Stat. 452.355, which grants the circuit court subject matter jurisdiction to enter an award of attorney fees on appeal while the appeal is pending, is not unconstitutional; (2) section 452.355 is not unconstitutionally vague because it provides sufficient guidance so as to allow a person of ordinary intelligence to understand the standards to be applied by the circuit court in making an award of attorney fees; and (3) the trial court did not abuse its discretion in awarding Wife attorney's fees on appeal. View "Goins v. Goins" on Justia Law

Driver was arrested for driving while intoxicated (DWI). The Director of Revenue (DOR) subsequently suspended Driver's license and disqualified him from driving a commercial motor vehicle. Driver filed a petition for a trial de novo in the trial court challenging the constitutional validity of Mo. Rev. Stat. 302.700 and 302.755, which disqualify drivers who are convicted of an alcohol-related traffic offense from driving a commercial vehicle for not less than one year. The trial court ruled that sections 302.500 and 302.700 violated the U.S. Constitution based on National Federation of Independent Business v. Sebelius (hereinafter NFIB) and reinstated Driver's driving privileges, including his commercial driver's license (CDL). The Supreme Court (1) reversed the trial court's judgment as to the constitutional validity of section 302.700 under NFIB, holding that NFIB was inapplicable to Driver's argument; and (2) denied Driver's due process and equal protection arguments, finding that they were without merit. View "Bone v. Dir. of Revenue" on Justia Law

After a jury trial, Defendant was convicted of two counts of sexual misconduct involving a child pursuant to Mo. Rev. Stat. 566.083 and two counts of attempted sexual misconduct involving a child. The convictions arose from incidents in which Defendant knowingly exposed his genitals to young girls from the front door or window of his house. Defendant appealed, arguing (1) section 566.083 is unconstitutionally overbroad because it infringes on activities protected by Fifth and Fourteenth Amendments, (2) the statute is unconstitutional as applied, and (3) insufficient evidence supported his convictions. The Supreme Court affirmed, holding (1) because Defendant failed to show how section 566.083 serves to discourage citizens from engaging in protected speech, Defendant failed to demonstrate that the statute is overbroad; (2) section 566.083 is constitutional as applied to Defendant; and (3) the evidence presented at trial was sufficient for a jury to convict Defendant of the crimes beyond a reasonable doubt. View "State v. Jeffrey" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to life imprisonment. The court of appeals affirmed Defendant's conviction and denied her motion for post-conviction relief. Approximately thirteen years later, Defendant filed a motion to re-open her post-conviction proceedings, claiming that she had been abandoned by her appointed counsel and that her conviction should be vacated to correct a manifest injustice. The motion court denied Defendant relief, finding that Defendant's motion was a prohibited successive motion. The Supreme Court affirmed after directing attorneys in such situations to file a motion for post-conviction relief due to abandonment, holding that the motion court did not clearly err in overruling Defendant's motion, as a motion to "re-open" does not exist in the Court's rules. View "Eastburn v. State" on Justia Law

After a trial, Defendant was convicted of misdemeanor criminal nonsupport. Defendant appealed, contending that the trial court erred in overruling his motion for judgment of acquittal claiming Mo. Rev. Stat. 568.040 violated his due process rights because it forced him to disprove an element of the offense. Specifically, Defendant asserted that section 568.040 was unconstitutional because it makes lack of good cause an element of the crime of criminal support but then shifts the burden of proving good cause to the defendant. The Supreme Court affirmed the conviction, holding (1) the statute makes lack of good cause an element of the offense that the State must prove beyond a reasonable doubt; and (2) sufficient evidence supported the trial judge's conclusion that Defendant's failure to pay the ordered child support was without good cause. View "State v. Holmes" on Justia Law

After the St. Louis Public School District (SLPS) became unaccredited in 2007 and was operated by the Transitional School District of St. Louis, some parents sought to have their children obtain Mo. Rev. Stat. 167.131 transfers that would enable the children to attend school in the Clayton school district. The parents (Plaintiffs) also requested that the transitional school district pay for their children's education in Clayton. The trial court held in favor of the school districts (Defendants). The Supreme Court reversed, holding that section 167.131, the "Unaccredited District Tuition Statute," was applicable to the transitional school district and required that it pay Plaintiffs' children's tuition costs for attending Clayton. On remand, the trial court allowed taxpayers from Clayton and SLPS to intervene. The trial court found in favor of Defendants, holding that section 167.131 was unenforceable as applied to Defendants because (1) it violated the Hancock Amendment of the Missouri Constitution, and (2) Defendants' compliance with the statute was impossible. The Supreme Court reversed, holding (1) section 167.131, as applied to Defendants, did not violate the Hancock Amendment; and (2) the trial court erred in finding it would be impossible for Defendants to comply with the requirements of the statute. Remanded. View "Breitenfeld v. Sch. Dist. of Clayton" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder and was sentenced to death for one of the murders. The Supreme Court reversed the death sentence and remanded the case for a retrial of the penalty phase. At the retrial, Defendant was again sentenced to death. Defendant subsequently filed a pro se Mo. R. Crim. P. 29.15 motion for post-conviction relief challenging various aspects of his penalty-phase retrial. The judge assigned to hear the Rule 29.15 motion had presided over Defendant's first trial, Defendant's first post-conviction motion hearing, and the penalty-phase retrial. The motion court overruled Defendant's second Rule 29.15 motion. The Supreme Court reversed, holding (1) the judge presiding over Defendant's post-conviction proceedings erred in overruling Defendant's motion to disqualify the judge for cause because a reasonable person could find an appearance of impropriety where the judge's references in the record to extrajudicial information in Defendant's first trial suggested that the judge relied on that information in ruling on Defendant's Rule 29.15 motion; and (2) therefore, recusal was required. Remanded. View "Anderson v. State" on Justia Law