Monday, August 23, 2010

State ex rel. Laughlin v. Bowersox[1]

Opinion handed down August 23, 2010
Link to Mo. Sup. Ct. Opinion

The Supreme Court of Missouri discharged a man after he served over fifteen years in prison for burglary and property damage after finding that the circuit court in which the man was convicted and sentenced lacked jurisdiction. The court held that federal courts should have heard the defendant’s case because the offense occurred on federal property and the defendant’s failure to raise the issue of jurisdiction in an earlier proceeding did not bar his petition for habeas corpus relief.

I. Facts and Holding

In 1993, the Newton County circuit court convicted Dwight Laughlin of first-degree burglary and first-degree property damage.[2] The crimes for which Laughlin was convicted occurred in the United States post office in Neosho, Missouri.[3] The state of Missouri’s jurisdiction over the land the Neosho post office occupies was ceded voluntarily to the federal government when the United States acquired the land in order to build the post office in 1933.[4]

The Newton County circuit court sentenced Laughlin to a forty-year aggregate sentence.[5] Laughlin subsequently appealed his conviction and also filed a Rule 29.15 motion to vacate the judgment while his appeal was pending.[6] In his Rule 29.15 motion, Laughlin argued that the circuit court lacked jurisdiction to try his case because his offense was exclusively federal and, thus, that the state court’s jurisdiction was preempted.[7] However, the circuit court denied this claim, stating that “‘[n]o evidence was adduced showing the offense was not a state offense or that the federal government had pre-empted jurisdiction.’”[8]

Laughlin appealed the circuit court’s overruling of his Rule 29.15 motion to the court of appeals, which consolidated his original appeal and his appeal from his Rule 29.15 motion.[9] However, the only issue that was raised on that appeal was whether he had received ineffective assistance of counsel.[10] The court of appeals affirmed the circuit court’s order denying post-conviction relief, but failed to address the issue of jurisdiction because Laughlin did not raise it at that time.[11]

In November 2009, Laughlin filed a petition for writ of habeas corpus, challenging the circuit court’s jurisdiction in his case.[12] The Supreme Court of Missouri granted the writ in March 2010 after Laughlin had sought relief in both the circuit court and court of appeals.[13]

The state argued that the matter of jurisdiction was already fully litigated and that Laughlin was bound by the judgment and his failure to raise the issue on appeal.[14] However, the Supreme Court of Missouri disagreed, discharging Laughlin and holding that, when a trial court lacks subject matter jurisdiction to try the defendant, the judgment must be discharged regardless of whether the issue of jurisdiction was raised in an earlier proceeding.[15]

II. Legal Background

A. Subject Matter Jurisdiction

Article V, section 14 of the Missouri Constitution provides that “circuit courts shall have original jurisdiction over all cases and matters, civil and criminal.”[16] This constitutional mandate means that Missouri courts have subject matter jurisdiction over criminal cases that occur in the state, including burglaries and property offenses.[17] However, because of the principles of federalism, federal law trumps state law. In addition, the United States Constitution declares in Article I, Section 8, Clause 17 that, if jurisdiction is ceded by the state, the United States gains exclusive authority over that land.[18] Thus, Missouri courts lack the authority to enforce state laws on federal property.[19]

More than just the purchase of land within a state by the United States is required in order for a state to be divested of its jurisdiction.[20] The state must actually cede jurisdiction to the United States.[21] Also, a state’s cession of jurisdiction to the United States need not be absolute.[22] The United States Supreme Court has held that a state may make its cession of jurisdiction absolute or qualified in a manner in which it finds desirable.[23] The state of Missouri met this requirement when it enacted both Missouri Revised Statutes section 12.010 and section 12.020.[24] Section 12.010 ratified Missouri’s consent to the federal government’s purchase of the land to establish and maintain a post office in Neosho, Missouri.[25] Section 12.020 acted to cede jurisdiction over that particular land to the United States; the only right reserved to the state of Missouri by the statute was the right to serve process on the property.[26] Therefore, the joint effect of these two statutes was to give the United States exclusive jurisdiction for all crimes occurring on the Neosho post office’s land.[27]

The state argued that Missouri had the jurisdiction to prosecute Laughlin because “his mens rea to commit his crimes was formed before he stepped onto the Neosho post office’s land and because the results of his crime affected events in the state of Missouri.”[28] However, the court quickly dismissed this argument, stating that a defendant’s mens rea is not conduct as required by the statute that the state relied on.[29]

Therefore, by enacting both of these statutes, the state of Missouri chose to give exclusive jurisdiction over the Neosho post office to the United States.[30] The Supreme Court of Missouri further concluded that, since Laughlin’s conduct occurred on the post office’s land, the state of Missouri lacked the subject matter jurisdiction to prosecute Laughlin for this conduct.[31]

B. Laughlin’s Habeas Claim

Relief for a petitioner through a writ of habeas corpus is available “‘when a person is held in detention in violation of the constitution or laws of the state or federal government.’”[32] Further, habeas relief is available for petitioners who can demonstrate: “(1) a claim of actual innocence or (2) a jurisdictional defect or (3)(a) that the procedural defect was caused by something external to the defense – that is, a cause for which the defense is not responsible – and (b) prejudice resulted from the underlying error that worked to the petitioner’s actual and substantial disadvantage.”[33] The Supreme Court of Missouri found that Laughlin was not barred from habeas relief because the court that convicted him did not have the subject matter jurisdiction to do so.[34]

The state argued that the issue of jurisdiction was already fully litigated in Laughlin’s Rule 29.15 motion, and since the issue was not subsequently raised again in his appeal of that motion, he was barred from bringing such a claim in a habeas proceeding.[35] However, the court quickly dismissed this notion stating that “[i]f a criminal judgment was entered by a court without jurisdiction to do so, such a proceeding always should be found to be void, whether determined on direct appeal or in a habeas proceeding.”[36] Further, the court declared that neither Laughlin’s counsel’s failure to raise the jurisdictional issue in an earlier appeal nor the passage of time conferred jurisdiction on the Newton County circuit court, when it never had subject matter jurisdiction in the first place.[37]

III. Comment

The Supreme Court of Missouri’s decision in State ex rel. Laughlin reaffirms the high importance that the law puts on procedural technicalities such as jurisdiction.[38] Here, a man who had already spent over fifteen years in prison was released on a procedural technicality rather than on any substantive issue regarding his innocence.

The court’s decision here exemplifies how ineffective the criminal justice system is when these procedural technicalities are overlooked and guilty individuals go free. However, as emphasized in this case, technicalities like jurisdiction are essential to ensure the fairness of the criminal justice system.[39] Further, the courts claiming jurisdiction and those which believe they should have jurisdiction are responsible for ensuring that criminal defendants are prosecuted in the correct court in order to avoid guilty individuals from going free due to lack of jurisdiction.

In the instant case, if the Newton County circuit court and the federal court that should have had jurisdiction had diligently monitored the situation, Laughlin would have been tried in the correct court and would not have been freed from prison as a result of a jurisdictional defect.

-Lindsay Ponce

[1] 318 S.W.3d 695 (Mo. 2010) (en banc).
[2] Id. at 697.
[3] Id. The post office is located at 101 E. Hickory, Neosho, Missouri. Id.
[4] Id. at 698-99.
[5] Id. Laughlin was sentenced to thirty years for the burglary and ten years for the property damage. Id.
[6] Id. at 697-98.
[7] Id.
[8] Id. at 698.
[9] Id.
[10] Id.
[11] Id.
[12] Id.
[13] Id.
[14] Id. at 697.
[15] Id. at 703.
[16] Mo. Const. art. V, § 14.
[17] Id.
[18] Laughlin, 318 S.W.3d at 699 (citing U.S. Const. art. I, § 8, cl. 17).
[19] Id.
[20] Id. (citing Fort Leavenworth R.R. Co. v. Lowe, 114 U.S. 525, 531 (1885)).
[21] Id.
[22] Id. at 699 (citing Surplus Trading Co. v. Cook, 281 U.S. 647, 652 (1930)).
[23] Id.
[24] Id. at 700 (citing Mo. Rev. Stat. § 12.010 (2000)).
[25] Id. (citing Mo. Rev. Stat. § 12.020 (2000)).
[26] Id.
[27] Laughlin, 318 S.W.3d at 700.
[28] Id. In making this argument, the state relied on Missouri Revised Statutes section 541.191(1), which provides that “this state has jurisdiction over an offense that a person commits by his own conduct of another for which such person is legally accountable if: (1) conduct constituting any element of the offense or a result of such conduct occurs within this state . . . .” Id. (citing Mo. Rev. Stat. § 541.191(1) (2000)).
[29] Id.
[30] Id.
[31] Id. at 701.
[32] Id. (quoting State ex rel. Zinna v. Steele, 301 S.W.3d 510, 516 (Mo. 2010) (en banc)).
[33] Id. at 702 (citing Zinna, 301 S.W.3d at 516-17).
[34] Id. at 703.
[35] Id. at 701.
[36] Id. at 703.
[37] Id.
[38] Laughlin, 318 S.W.3d 695.
[39] Id. at 702.