Mary Fox, Respondents/Cross-Appellants v. State of Missouri, Appellants/Cross-Respondents.

CourtSupreme Court of Missouri
DecidedMarch 15, 2022
DocketSC98909
StatusPublished

This text of Mary Fox, Respondents/Cross-Appellants v. State of Missouri, Appellants/Cross-Respondents. (Mary Fox, Respondents/Cross-Appellants v. State of Missouri, Appellants/Cross-Respondents.) 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
Mary Fox, Respondents/Cross-Appellants v. State of Missouri, Appellants/Cross-Respondents., (Mo. 2022).

Opinion

SUPREME COURT OF MISSOURI en banc MARY FOX, et al., ) Opinion issued March 15, 2022 ) Respondents/Cross-Appellants, ) ) v. ) No. SC98909 ) STATE OF MISSOURI, et al., ) ) Appellants/Cross-Respondents. )

APPEAL FROM THE CIRCUIT COURT OF COLE COUNTY The Honorable Patricia S. Joyce, Judge

Five public defenders and three criminal defendants filed an action for declaratory

and injunctive relief, challenging the constitutional validity of certain statutes that relate

to victims of sexual offenses. The provisions were enacted by Senate Bill No. 569 (“SB

569”) in 2020. Most importantly, the action attacked section 595.201, 1 which requires

criminal defense attorneys to provide information to victims of sexual assault offenses.

The circuit court 1) determined section 595.201 violated defense attorneys’ rights to

freedom of speech, 2) declared it constitutionally invalid as applied to defense counsel,

and 3) enjoined its enforcement. The circuit court, however, rejected various challenges

1 All statutory references are to RSMo Supp. 2020, unless otherwise specified. to SB 569 as a whole by holding passage of the law did not violate procedural

limitations—namely, the original purpose, clear title, and single subject requirements—

imposed by the Missouri Constitution. The judgment is affirmed.

Background

In 2020, the General Assembly passed legislation addressing issues relating to

victims of sexual assault offenses. SB 569, upon introduction, concerned evidentiary

collection kits in sexual assault cases. 2 Before final approval, four provisions—including

section 595.201.2(4), which is of particular importance in this case—were added. 3 That

provision states:

Before commencing an interview of a survivor, a law enforcement officer, prosecuting attorney, or defense attorney shall inform the survivor of the following:

(a) The survivor’s rights pursuant to this section and other rules and regulations by the department of public safety and the department of health and senior services, which shall be signed by the survivor of sexual assault to confirm receipt;

(b) The survivor’s right to consult with an employee or volunteer of a rape crisis center during any interview by a law enforcement official, prosecuting attorney, or defense attorney, to be summoned by the interviewer before the commencement of the interview, unless no employee or volunteer of a rape crisis center can be summoned in a reasonably timely manner;

2 Initially, the legislation modified section 595.220 by creating an electronic system that allowed sexual assault victims to track and obtain information regarding the status of their evidentiary collection kits. It also established other rules and guidelines relevant to the system. 3 The other amendments established sections 195.2520, 197.135, and 595.202. Respectively, those statutes 1) created a telehealth network for conducting forensic examinations in sexual offense cases; 2) established requirements for certain hospitals regarding forensic examinations in sexual offense cases and allowed patients to waive the requirements; and 3) created a task force to study and recommend best practices regarding various aspects of addressing sexual offenses cases. 2 (c) The survivor’s right to have a support person of the survivor’s choosing present during any interview by a law enforcement officer, prosecuting attorney, or defense attorney, unless the law enforcement officer, prosecuting attorney, or defense attorney determines in his or her good faith professional judgment that the presence of that individual would be detrimental to the purpose of the interview; and

(d) For interviews by a law enforcement officer, the survivor’s right to be interviewed by a law enforcement official of the gender of the survivor’s choosing. If no law enforcement official of that gender is reasonably available, the survivor shall be interviewed by an available law enforcement official only upon the survivor’s consent[.]

In August 2020, one day before the effective date of the legislation, individuals

associated with the Missouri State Public Defender—Mary Fox, Megan Beesley, Paige

Bremner, Erich Fonke, and Brian Horneyer—and criminal defendants—Dawan

Ferguson, Sean Williams, and Donnell Jackson—(collectively, “Challengers”) filed an

action for declaratory and injunctive relief against the State of Missouri and Attorney

General Eric Schmitt (collectively, the “State”). They alleged section 595.201 violated

1) defense attorneys’ right to freedom of speech under the federal and state constitutions;

2) separation of powers principles under the Missouri Constitution; 3) this Court’s ability

to regulate the legal profession under the Missouri Constitution; 4) criminal defendants’

rights to counsel and confrontation under the federal constitution; and 5) criminal

defendants’ rights to due process and counsel under the Missouri Constitution.

Challengers further contended SB 569 violated the original purpose, reading, clear title,

and single subject requirements of the Missouri Constitution. The circuit court issued a

temporary restraining order prohibiting enforcement of section 595.201 against defense

attorneys.

3 Challengers moved for a preliminary injunction. At a hearing, three individuals—

Mary Fox, Megan Beesley, and Erich Fonke—testified for Challengers. They explained

that informing victims about the rights contained in section 595.201.2(4) would adversely

affect representation of their clients. Fox indicated complying with the provision would

create an impression that defense attorneys were working for the prosecution, create

conflicts of interest, and violate other duties to clients. She testified attorney-client

relationships would likely be harmed. Beesley also indicated complying with the

statutory requirements would be adverse to client interests. Fox also expressed concern

regarding section 595.201.3(11)’s definition of “survivor,” indicating she may need to

provide the required information to many individuals in various contexts.

Laura Dunn, an expert regarding sexual assault victims’ rights, testified for the

State. She explained sexual assault victims often report having negative interactions with

aspects of the criminal justice system, including dealings with prosecutors and defense

attorneys, which can create secondary trauma and reduce cooperation. Dunn stated

survivors are more willing to engage in the process when support advocates are present.

She testified that, for survivors to make use of the rights listed in section 595.201.2(4),

they must receive information prior to the interview. Dunn opined measures other than

providing the rights directly before the beginning of an interview would be ineffective.

She said survivors are often confused and traumatized, which may hinder their ability to

retain information over time. Dunn did not provide specific evidence of interactions with

defense attorneys creating secondary trauma and was unaware of other victims’ rights

bills that required defense attorneys to provide information.

4 The circuit court sustained Challengers’ motion for a preliminary injunction.

Challengers and the State later agreed to an amended temporary restraining order, which

was extended until the entry of a final judgment. Subsequently, the circuit court issued a

judgment and memorandum opinion, which found for Challengers on all substantive

constitutional claims 4 and declared section 595.201 constitutionally invalid as applied to

defense attorneys.

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Mary Fox, Respondents/Cross-Appellants v. State of Missouri, Appellants/Cross-Respondents., Counsel Stack Legal Research, https://law.counselstack.com/opinion/mary-fox-respondentscross-appellants-v-state-of-missouri-mo-2022.