Case Summary for May 5, 2010

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Case Summary for May 5, 2010

THE FOLLOWING DOCKET SUMMARIES ARE PREPARED BY THE COURT'S STAFF FOR THE INTEREST AND CONVENIENCE OF THE READER. THE SUMMARIES MAY NOT INCLUDE ALL ISSUES PENDING BEFORE THE COURT AND DO NOT REFLECT ANY OPINION OF THE COURT ON THE MERITS OF A CASE. COPIES OF ALL BRIEFS FILED WITH THE COURT ARE AVAILABLE AT THE SUPREME COURT BUILDING, COURT EN BANC DIVISION. SUMMARIES ARE UNOFFICIAL AND SHOULD NOT BE QUOTED OR CITED.

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DOCKET SUMMARIES
SUPREME COURT OF MISSOURI

9 a.m. Wednesday, May 5, 2010

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SC90542
State ex rel. Dwight Laughlin v. Michael Bowersox
Newton County
Jurisdiction for post office
Listen to the oral argument:

Laughlin was represented during argument by Ginger K. Gooch of Husch Blackwell Sanders LLP in Springfield, and the state was represented by Andrew W. Hassell of the attorney general's office in Jefferson City.

Dwight Laughlin was charged as a prior and persistent offender in April 1993 in Newton County with one count of first-degree burglary and one count of first-degree property damage, both felonies. The state alleged Laughlin broke into a United States post office in Neosho and damaged a safe. In May 1993, he was found guilty and sentenced to 40 years in prison. Laughlin moved for postconviction relief, alleging the trial court had lacked jurisdiction. His motion was overruled. Laughlin seeks this Court’s writ of habeas corpus.

Laughlin argues the trial court lacked jurisdiction, contending the federal courts have exclusive jurisdiction over his case. He asserts the alleged crimes occurred in the United States post office, a federal enclave over which federal courts have exclusive jurisdiction pursuant to article I, section 8, clause 17 of the United States Constitution and section 12.010 and 12.020, RSMo. Laughlin argues his trial counsel failed to raise the lack of jurisdiction as a defense and this failure prejudiced Laughlin.

The state responds that Laughlin’s claim is an improper successive claim. It contends that the circuit court overruled his postconviction motion that the trial court lacked jurisdiction and that Laughlin did not appeal that decision. The state asserts Laughlin cannot assert the lack of jurisdiction a second time. It argues the trial court had jurisdiction because the Missouri legislature allows for jurisdiction when the intent to commit the crime and the crime occurred in the state and the conduct constituted an offense that is an offense under state laws.

SC90528
State of Missouri v. Tyrone C. Bateman
City of St. Louis
Challenge to jury selection
Listen to the oral argument:

Bateman was represented during argument by Jessica M. Hathaway of the public defender's office in St. Louis, and the state was represented by Richard A. Starnes of the attorney general's office in Jefferson City.

In March 2005, Tyrone Bateman and his cousin had an argument over money. The cousin hit Bateman in the head with a tire iron. Bateman left the scene and returned with a shotgun. He broke down a door and shot his cousin. The cousin died three weeks later. Bateman was charged with first-degree murder and armed criminal action. During jury selection for Bateman’s May 2007 trial, the prosecutor used peremptory strikes (these strikes allow parties to reject some potential jurors without explanation) to remove four individuals from the jury pool. All four individuals were black. Bateman alleged one of the strikes was motivated solely by race and, therefore, violated the equal protection clause of the United States Constitution pursuant to Batson v. Kentucky, 476 U.S. 79 (1986). The trial court sustained the challenge. The prosecutor then struck another potential juror who was black and Bateman again lodged a Batson challenge, but the trial court overruled the motion after the prosecutor provided a race-neutral reason for striking the potential juror. The prosecutor argued the potential juror had asked about different degrees of murder and might be more lenient. At trial, the prosecutor argued Bateman knowingly caused his cousin’s death after deliberation or cool reflection. Bateman acknowledge he caused his cousin’s death but argued that he was not guilty of first-degree murder and that the evidence supported a conviction of the lesser-included offense of voluntary manslaughter. After the close of all evidence, Bateman moved for judgment of acquittal, arguing there was insufficient evidence to convict him of the charged crimes. The trial court overruled his motion. In June 2007, Bateman was convicted of first-degree murder and armed criminal action. He was sentenced to life in prison without the possibility of parole for murder and a consecutive term of 10 years in prison for armed criminal action. Bateman appeals.

Bateman argues the trial court violated his right to due process of law as guaranteed by the United States and Missouri constitutions. He contends there was insufficient evidence to support a reasonable inference he coolly reflected prior to shooting his cousin. Bateman further argues the trial court violated his constitutional rights to equal protection and a fair trial when it overruled his objection to the state’s peremptory strike of a potential juror who was black. He asserts the state’s peremptory strike was motivated by race in violation of Batson. Bateman contends the prosecutor did not strike a potential juror who was white who raised the same questions as the potential juror who was black and was struck from the jury pool.

The state responds the trial court did not err in entering judgment against Bateman on the jury’s finding of guilt on the first-degree murder charge because there was sufficient evidence that Bateman deliberated prior to murdering his cousin. The state contends Bateman’s actions before, during and after the murder demonstrated that he coolly reflected prior to killing his cousin because he drove away after their first altercation, got a shotgun, drove back to the scene, broke down a door and then shot his cousin. The state argues the trial court did not err in overruling Bateman’s Batson challenge to the prosecutor’s peremptory strike. It contends the prosecutor’s explanation for the strike was reasonably related to the state’s interest in obtaining a first-degree murder conviction, there were no other similarly situated potential jurors not struck by the state, and the prosecutor did not use all of the available strikes against people who were black.