In re: Circuit Attorney, 22nd Judicial Circuit ex rel. Christopher Dunn

CourtSupreme Court of Missouri
DecidedApril 15, 2025
DocketSC100878
StatusPublished

This text of In re: Circuit Attorney, 22nd Judicial Circuit ex rel. Christopher Dunn (In re: Circuit Attorney, 22nd Judicial Circuit ex rel. Christopher Dunn) is published on Counsel Stack Legal Research, covering Supreme Court of Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re: Circuit Attorney, 22nd Judicial Circuit ex rel. Christopher Dunn, (Mo. 2025).

Opinion

SUPREME COURT OF MISSOURI en banc

IN RE: CIRCUIT ATTORNEY, 22nd ) Opinion issued April 15, 2025 JUDICIAL CIRCUIT EX REL. ) CHRISTOPHER DUNN, ) No. SC100878 ) Respondent. )

APPEAL FROM THE CIRCUIT COURT OF THE CITY OF ST. LOUIS The Honorable Jason M. Sengheiser, Judge

This Court granted the State of Missouri’s transfer application and ordered the

cause transferred prior to opinion by the court of appeals as to the issue raised in the court

of appeals’ show cause order—whether the State of Missouri has the right to appeal a

judgment vacating or setting aside a conviction under section 547.031. 1 This Court holds

the State of Missouri is an aggrieved party with a statutory right to appeal under section

512.020(5) and retransfers this cause to the court of appeals to overrule the circuit

attorney’s motion to dismiss and proceed with the state’s appeal on the merits.

1 All references to sections 56.087 and 512.020 are to RSMo 2016, and all other statutory references are to RSMo Supp. 2023 unless otherwise noted. All rule references are to Missouri Court Rules (2024). The Court granted transfer prior to opinion of the court of appeals due to the general interest and importance of the issue raised. Section 547.031 has been amended effective August 28, 2024, but the amendment does not concern the issue in this appeal. Factual Background and Procedural History

In July 1991, a circuit court found Christopher Dunn guilty, after a jury trial, of

first-degree murder, two counts of first-degree assault, and three counts of armed criminal

action and sentenced him as a prior and persistent offender to life in prison without parole

for the murder offense, 30 years’ imprisonment for each of the assault offenses, and 10

years’ imprisonment for each of the armed criminal action offenses, with all sentences to

be served consecutively.

In February 2024, the St. Louis circuit attorney filed a motion to vacate or set

aside Dunn’s convictions under section 547.031. The attorney general entered his

appearance and opposed the motion. On July 22, 2024, the circuit court entered its

judgment concluding, after an evidentiary hearing as required by section 547.031.2, the

circuit attorney had established “a clear and convincing showing of ‘actual innocence’

that undermines the basis for Dunn’s convictions because in light of the new evidence, no

juror, acting reasonably, would have voted to find Dunn guilty of these crimes beyond a

reasonable doubt.” The circuit court sustained the motion, vacated Dunn’s convictions,

and ordered his immediate discharge from custody. The attorney general filed a notice of

appeal.

On July 24, 2024, the circuit court entered its order requiring Dunn’s release from

prison by 6 p.m. that day. The attorney general filed in this Court a petition for a writ of

prohibition or mandamus to prevent the circuit court from ordering Dunn’s unconditional

release. The attorney general also asked for an emergency stay to allow sufficient time

for this Court to consider the writ petition. This Court issued an order temporarily

2 staying the circuit court proceedings and requested expedited briefing on the merits of the

writ petition. After briefing and argument, this Court issued its opinion holding the

circuit court lacked authority to unconditionally release Dunn while criminal charges

remained pending and issued a permanent writ prohibiting the circuit court from ordering

Dunn’s release without allowing the State of Missouri to indicate its intent to retry him.

State ex rel. Bailey v. Sengheiser, 692 S.W.3d 20, 26 (Mo. banc 2024).

On July 30, 2024, the circuit court entered its amended judgment vacating the part

of its order requiring Dunn’s release by 6 p.m. on July 24, 2024. The circuit attorney

filed a memorandum of nolle prosequi, and the state released Dunn from prison on July

30, 2024. 2 The attorney general filed a notice of appeal. The circuit attorney moved to

dismiss the appeal, asserting the state has no right to appeal under section 547.031.

In December 2024, the court of appeals issued a show cause order directing the

parties to file memoranda addressing whether the State of Missouri has the right to appeal

or whether the appeal should be dismissed. The attorney general sought transfer in this

Court prior to opinion by the court of appeals. Mo. Const. art. V, sec. 10. This Court

granted the application and ordered the cause transferred as to the issue in the court of

appeals’ show cause order—whether the State of Missouri has the right to appeal a

judgment sustaining a motion under section 547.031.

2 “A nolle prosequi is a prosecutor’s formal entry on the record indicating that he or she will no longer prosecute a pending criminal charge.” State v. Sisco, 458 S.W.3d 304, 310 (Mo. banc 2015) (internal quotation omitted); sec. 56.087 (codifying nolle prosequi).

3 Standard of Review

“The right to appeal derives solely from statute.” State v. Johnson, 617 S.W.3d

439, 443 (Mo. banc 2021). “If a statute does not give a right to appeal, the appeal must

be dismissed.” Id. (internal quotation omitted); see also Rule 81.01 (“The right of appeal

shall be as provided by law.”). Whether a statute gives a right to appeal is a question of

statutory interpretation, which is an issue of law the Court reviews de novo. Ramirez v.

Mo. Prosecuting Att’ys’ & Cir. Att’ys’ Ret. Sys., 694 S.W.3d 432, 435 (Mo. banc 2024).

Analysis

“This Court has held that proceedings under section 547.031 are a collateral attack

on a criminal judgment and sentence and are civil in nature.” Sengheiser, 692 S.W.3d at

23. A section 547.031 motion “is not part of the original criminal case regardless of how

it is docketed or referred to in the circuit court.” State ex rel. Bailey v. Fulton, 659

S.W.3d 909, 913 n.3 (Mo. banc 2023) (internal quotation omitted).

Section 512.020 governs the right to appeal in civil actions generally. Section

512.020(5) grants the right to appeal any final judgment or any special order after final

judgment to “[a]ny party to a suit aggrieved by any judgment of any trial court in any

civil cause from which an appeal is not prohibited by the constitution, nor clearly limited

in special statutory proceedings[.]” “This Court has long held appeals are favored in the

law and statutes granting appeals are liberally construed.” Meadowfresh Sols. USA, LLC

v. Maple Grove Farms, LLC, 578 S.W.3d 758, 760 (Mo. banc 2019) (internal quotation

and alteration omitted).

4 No party disputes the circuit court’s amended judgment is a final judgment.

Likewise, no party contends the constitution prohibits the state’s appeal. 3 The state has

the right to appeal under section 512.020(5), therefore, if it is a party to the suit and is

aggrieved by the circuit court’s judgment. 4

3 Even assuming section 547.031 is a special statutory proceeding, an issue this Court need not decide, section 547.031 by its silence as to the state’s right to appeal does not clearly limit or take away the state’s right to appeal under section 512.020(5) as an aggrieved party to a final judgment.

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In re: Circuit Attorney, 22nd Judicial Circuit ex rel. Christopher Dunn, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-circuit-attorney-22nd-judicial-circuit-ex-rel-christopher-dunn-mo-2025.