Justia Constitutional Law Opinion Summaries

The Supreme Court affirmed Defendant's conviction of felony possession of a controlled substance, holding that the circuit court did not err in admitting evidence obtained from Defendant's statements and a search of his vehicle after a traffic stop.On appeal, Defendant argued that the circuit court erred in overruling his motion to suppress because the traffic stop was unreasonable and violated the Fourth Amendment. The Supreme Court affirmed, holding (1) crossing the fog line and driving on the shoulder is a traffic violation and creates a lawful justification for a traffic stop; and (2) the stop in this case was justified after Defendant's vehicle crossed the fog line and drove on the shoulder and therefore did not constitute an unreasonable seizure under the Fourth Amendment. View "State v. Smith" on Justia Law

The Supreme Court affirmed the judgment of the circuit court granting summary judgment in favor of the State and intervenors (collectively, Defendants) on the City of Chesterfield's action seeking a declaration that Mo. Rev. Stat. 66.600 and 66.620 are constitutionally invalid special laws, holding that sections 66.600 and 66.620 are not special laws.On appeal, Chesterfield argued that the trial court erred in failing to find that the statutes were constitutionally invalid special laws because the general assembly changed the population classification of section 66.600 to exclude St. Charles County, and that 66.620 creates a closed class based on immutable, historical, and geographic facts and is not substantially justified. The Supreme Court affirmed, holding that the circuit court did not err in granting summary judgment for Defendants because Defendants articulated a rational basis for the classifications in sections 66.600 and 66.200. View "City of Chesterfield v. State" on Justia Law

The Supreme Court affirmed the judgment of the motion court denying Defendant's motion for postconviction relief filed under Mo. R. Crim. P. 29.15, holding that the motion court did not err in denying postconviction relief.Defendant was convicted of murder in the first degree, armed criminal action, burglary in the first degree, and unlawful possession of a firearm by a felon. The trial court sentenced Defendant to death. Defendant later moved for postconviction relief, alleging ineffective assistance of counsel. The motion court denied the postconviction motion. The Supreme Court affirmed, holding that the motion court did not err in denying Defendant's claims. View "Hosier v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court affirming the decision of the Administrative Hearing Commission (AHC), which found cause to discipline Appellant's license as a peace officer, and the subsequent order of the Missouri Director of the Department of Public Safety, which permanently revoked Appellant's license, holding that Mo. Rev. Stat. 590.080 is valid.On appeal, Appellant argued that section 590.080, under which the AHC may find that cause for discipline exists of the licensee has committed a criminal offense, whether or not a criminal charge has been filed, violates principles of separation of powers embodied in Mo. Const. art. II, 1. Appellant further argued that the order of the Director revoking his license was not supported by competent and substantial evidence. The Supreme Court affirmed, holding (1) nothing in section 590.080 violates the separation of powers provision; and (2) there was ample competent and substantial evidence for the Director to conclude that continuing to license Appellant as a peace officer would not adequately protect the public. View "O'Brien v. Department of Public Safety" on Justia Law

The Supreme Court reversed the judgment of the motion court to the extent it overruled Appellant's motion for postcondition relief on his driving while revoked conviction and affirmed the judgment in all other respects, holding that appellate counsel's failure to raise a sufficiency of evidence claim constituted deficient performance that prejudiced Appellant.Appellant was convicted of driving while intoxicated and driving while revoked. In his Mo. R. Civ. P. 29.15 motion for postconviction relief Appellant argued that his trial counsel was ineffective for failing to call his physician to testify that certain prescription medications he took made him appear intoxicated by alcohol the night he was arrested and that appellate counsel was ineffective for failing to argue there was insufficient evidence to enhance his driving while revoked misdemeanor to a felony. The Supreme Court agreed and reversed in part, holding (1) Appellant's postconviction relief claim relating to his driving while intoxicated conviction was properly denied because there was no reasonable probability the trial court's finding would have been different had the physician testified at Appellant's trial; and (2) appellate counsel's failure to raise the sufficiency of the evidence claim constituted deficient performance by which Appellant was prejudiced. View "Hounihan v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court affirming the constitutional validity of Senate Bill. No. 638 (SB 638) and Senate Bill 665 (SB 665), holding that the bills do not violate Mo. Const. art. III, 21 or 23 and that Appellant failed to state a claim for relief regarding his substantive title change claim.Specifically, Appellant argued (1) the original purpose of the bills were changed by amendments such that, as enacted, the bills violated article III, section 21; (2) the final bills violated the single subject requirement of article III, section 23; and (3) the substantive changes to the bills' titles during the legislative process violated article III, sections 21 and 23. The Supreme Court affirmed, holding (1) the bills maintained their original purpose throughout the legislative process; (2) the bills did not violate the single subject requirement; and (3) the circuit court did not err in dismissing Appellant's substantive title change claim for failing to state a claim. View "Calzone v. Interim Commissioner of the Department of Elementary and Secondary Education Roger Dorson" on Justia Law

The Supreme Court affirmed the judgment of the motion court overruling Defendant's Rule 29.15 motion for post conviction relief without an evidentiary hearing, holding that Defendant failed to plead facts showing his counsel was ineffective.In his Rule 29.15 motion Defendant claimed that his trial counsel provided ineffective assistance by failing to seek suppression of methamphetamine found during a warrantless search of a cigarette pack seized from his pocket on the grounds that the search occurred thirty minutes after his arrest in an area outside his immediate control. The motion court overruled the motion. The Supreme Court affirmed, holding that the search of Defendant's cigarette was a lawful search incident to arrest, and therefore, Defendant failed to plead facts showing his counsel was ineffective in not challenging the search. View "Greene v. State" on Justia Law

In this appeal from the circuit court's finding that D.C.M. committed an act that, if committed by an adult, would have constituted the felony of making a terrorist threat in the second degree, the Supreme Court remanded this case to the circuit court for an evidentiary hearing to determine whether counsel was ineffective and otherwise affirmed the judgment, holding that the record was insufficient to determine whether counsel was ineffective.D.C.M. was sitting in a school cafeteria when he told another student that he felt like "blowing the school up" or wanted to see how it felt to "shoot the school up." Based on this evidence, the circuit court placed D.C.M. in the custody of the division of youth services for an indefinite term. The Supreme Court held (1) D.C.M.'s ineffective assistance of counsel claims could not be addressed on direct appeal because the record was insufficient to address these claims; (2) the circuit court did not abuse its discretion in denying counsel's request for a continuance; and (3) there was sufficient evidence for the circuit court to find beyond a reasonable doubt that D.C.M. committed an act which, if committed by an adult, would have constituted the felony of making a terrorist threat in the second degree. View "D.C.M. v. Pemiscot County Juvenile Office" on Justia Law

The Supreme Court affirmed the judgment of the circuit court finding Defendant guilty of the first-degree murder of a ten-year-old girl and sentencing him to death, holding that none of Defendant's assignments of error warranted reversal.Specifically, the Court held that the circuit court did not abuse its discretion by (1) overruling Defendant's objection to the admission of photographs from the victim's cellphone; (2) admitting gun evidence found in Defendant's home; (3) admitting the contents of a folder containing photos of Defendant's female, middle school students and accounts of fictional sexual encounters with thirteen-year-old girls; (4) admitting victim impact evidence; (5) permitting the State to argue during closing argument that the jury could speak for the victim and her family by sentencing Defendant to death; and (6) sustaining the State's motion to strike a venire person for cause during the death qualification voir dire. Further, Defendant's constitutional arguments were unavailing, and Defendant's death sentence met all the statutory requirements. View "State v. Wood" on Justia Law

The Supreme Court affirmed the judgment of the motion court accepting Defendant's guilty plea to first-degree murder, first-degree robbery, and armed criminal action and sentencing him to life imprisonment without the possibility of parole, holding that Defendant's counsel was effective and that Defendant's plea was entered knowingly and voluntarily.After the circuit court imposed the sentence Defendant filed a motion for postconviction relief alleging, among other things, that his counsel was ineffective, and therefore, his plea was not entered knowingly and voluntarily. The Supreme Court affirmed, holding (1) Defendant was not coerced into accepting the State's plea agreement; (2) Defendant was competent to plead guilty; and (3) counsel was not ineffective for declining to seek a second competency examination. View "Johnson v. State" on Justia Law