Justia Constitutional Law Opinion Summaries

The Supreme Court dismissed this appeal brought by the State of an order and judgment dismissing with prejudice criminal charges against Defendant, holding that there was no final, appealable judgment, and therefore, the State lacked statutory authority to appeal pursuant to Mo. Rev. Stat. 547.200.Defendant, who was charged with second-degree murder, first-degree robbery, and armed criminal action, filed a motion to dismiss the indictment. The circuit court sustained the motion in part and dismissed the murder and robbery charges with prejudice, concluding that the Double Jeopardy Clause precluded those charges. The State appealed. The Supreme Court dismissed the appeal, holding that this was an improper appeal. View "State v. Harris" on Justia Law

The Supreme Court granted a writ of prohibition barring the circuit court from taking any further action in Petitioner's criminal case other than dismissing the pending charges against him, holding that the Interstate Agreement on Detainers (IAD) mandated dismissal of Petitioner's case.As a basis for the writ, Petitioner claimed that the circuit court violated the IAD by continuing his criminal case and failing to conduct a trial within 180 days of his request to dispose of his pending charges of rape, sodomy, and sexual abuse. The Supreme Court agreed and granted the writ, holding (1) the IAD applied to the disposition of the state charges pending against Petitioner resulting in a detainer being lodged with the federal penitentiary where he was serving a federal sentence; (2) the State waived any post hoc objection as to the sufficiency of Petitioner's request to dispose of his pending charges; (3) good cause did not exist under the IAD warranting continuing Petitioner's trial; and (4) Petitioner's actions did not waive, toll or otherwise justify extending the timeline mandated by the IAD. View "State ex rel. Wishom v. Honorable Bryant" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Caitlyn Williams and Tamara LaRue (together, Parents) of failing to cause their children to attend school on a regular basis in violation of Missouri's compulsory attendance law, holding that Mo. Rev. Stat. 167.031.1 was not unconstitutionally vague as applied in this case.On appeal, Parents argued, among other things, that the State failed to prove beyond a reasonable doubt both that their conduct was a purposeful or knowing violation of Mo. Rev. Stat. 167.031.1 and that the children's attendance was not sufficiently "regular" to constitute a statutory violation. The Supreme Court affirmed, holding (1) section 167.031.1 was not unconstitutionally vague as applied to the facts of this case; and (2) there sufficient evidence to find that Parents knowingly failed to cause their children to attend school on a regular basis after their children were enrolled. View "State v. LaRue" on Justia Law

The Supreme Court vacated the decision of the circuit court sustaining Defendant's motions to suppress evidence obtained after his warrantless arrest for a felony, holding that to the extent the decision was based on Defendant's claim that the Fourth Amendment is violated when an arresting officer was outside of the officer's jurisdiction unless the officer personally observed the crime, the decision was clearly erroneous.Defendant was charged in two separate cases for his involvement in two robberies. Defendant moved to suppress evidence obtained after a warrantless arrest, arguing that his Fourth Amendment rights were violated because the officer was outside of his jurisdiction. The circuit court sustained the motions to suppress. The Supreme Court vacated the circuit court's decision, holding that while Moore v. State, 458 S.W.3d 822 (Mo. banc 2015), requires both probable cause and that the crime be committed in the officer's presence for an arrest to satisfy the Fourth Amendment, when a warrantless arrest is for a felony, the Fourth Amendment is satisfied if the arresting officer has probable cause for the arrest, even when the felony was not committed in the arresting officer's presence. View "State v. Barton" on Justia Law

The Supreme Court affirmed the judgment of the circuit court, holding that the Missouri Constitution does not permit the General Assembly to limit the Conservation Commission's authority to expend and use conservation funds for constitutionally-enumerated purposes.The General Assembly enacted House Bill No. 2019 in 2020, appropriating $21 million to the Conservation Commission. The General Assembly, however, removed language from HB 2019 regarding use of the Commission's funds, including for land acquisition and payments in lieu of taxes (PILT). Later, the Commission attempted to withdraw funds to pay for a land acquisition and for PILT, but the Office of Administration denied the requests. The Commission and the Missouri Department of Conservation brought this action against the Attorney General and the Commissioner of the Office of Administration seeking declaratory relief to require certification of PILT payments. The circuit court ordered the Commissioner to certify the land purchase and PILT payments as requested. The Supreme Court affirmed, holding that, in passing HB 2019, the General Assembly invaded the Commission's constitutional authority by attempting to limit the constitutionally-enumerated purposes for which the Commission could use its funds. View "Conservation Comm'n v. Bailey" on Justia Law

The Supreme Court affirmed Defendant's conviction for first-degree statutory sodomy, incest, first-degree child molestation, and one count of first-degree attempted rape, holding that the circuit court's jury instructions did not violate Defendant's constitutional right to a unanimous verdict.On appeal, Defendant argued that the evidence presented at trial included multiple allegations of abuse related to each count of sexual misconduct and that five separate verdict directors violated his constitutional right to a unanimous jury verdict. The Supreme Court affirmed, holding that the jury instructions violated Defendant's right to a unanimous verdict. View "State v. Hamby" on Justia Law

The Supreme Court affirmed the order of the circuit court overruling Appellants' motion to vacate the court's order appointing a receiver for Appellants, holding that the petition filed by Patriots Bank seeking the appointment of a receiver pursuant to the Missouri Commercial Receivership Act (MCRA), Mo. Rev. Stat. 515.500-515.665, did not violate due process.Bank entered into lending relationships with Appellants, all of which defaulted. Bank filed a petition seeking the appointment of a receiver for Appellants. The circuit court entered the receiver order. The Supreme Court affirmed, holding (1) the Bank complied with the plain language of the MCRA's notice requirement; (2) the application of the MCRA to Appellants' case did not violate the due process protections under either the state or federal constitutions; (3) the circuit court did not abuse its discretion in overruling Appellants' motion to vacate the receiver order; and (4) the receiver order did not violate the MCRA. View "Black River Motel, LLC v. Patriots Bank" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of possessing a controlled substance, in violation of Mo. Rev. Stat. 579.015.1, and unlawfully using a weapon while in possession of a controlled substance, in violation of Mo. Rev. Stat. 571.030.1, holding that Defendant's convictions did not infringe upon his right to be free from double jeopardy.On appeal, Defendant argued that his convictions violated double jeopardy protections because they arose from the same conduct. The Supreme Court reversed, holding that no double jeopardy violation existed because the plain language of the states combined with fundamental principles of statutory interpretation clearly demonstrated the legislature's intent to authorize multiple punishments under sections 579.015 and 571.030.1(11). View "State v. Onyejiaka" on Justia Law

The Supreme Court denied Petitioner's petition seeking a writ prohibiting his execution and to appoint a special master to conduct an evidentiary hearing on his incompetency claim, holding that Petitioner did not demonstrate the required "substantial threshold showing of insanity" and that his mental illness claims were procedurally barred.On April 19, 2023, the Supreme Court issued a warrant for Petitioner's execution. One month later, Petitioner filed a petition for a writ of habeas corpus claiming that his execution would violate the Eighth and Fourteenth Amendments because he was incompetent to be executed under the standard set forth in Panetti v. Quarterman, 551 U.S. 930 (2007), and Ford v. Wainwright, 477 U.S. 399 (1986), and because he was severely mentally ill. Petitioner asked the Supreme Court to issue a writ prohibiting his execution and to appoint a special master to conduct an evidentiary hearing on his incompetency claim and filed a motion for a stay of execution while his incompetency claim was adjudicated. The Supreme Court denied Petitioner's habeas petition and overruled as moot his accompanying motion for a stay of execution, holding that Petitioner did not demonstrate the substantial threshold showing of insanity required by Panetti and Ford. View "State ex rel. Johnson v. Vandergriff" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of one count of kidnapping in the first degree and one count of committing violence against an employee of the Department of Corrections, holding that there was no plain error in the proceedings below.On appeal, Defendant argued that the circuit court erred in failing to conduct a sufficient Faretta hearing to ensure his waiver of counsel was knowing, intelligent, and voluntary and in ordering his sentence to consecutively to his prior sentence, in violation of his plea agreement with the State. The Supreme Court affirmed, holding (1) Defendant failed to demonstrate that the circuit court plainly erred in sustaining Defendant's request to represent himself; and (2) the circuit court did not err in ordering Defendant's sentences to run consecutively. View "State v. Teter" on Justia Law