State ex rel. Michael Kelly v. Julie Inman

CourtSupreme Court of Missouri
DecidedJanuary 14, 2020
DocketSC97744
StatusPublished

This text of State ex rel. Michael Kelly v. Julie Inman (State ex rel. Michael Kelly v. Julie Inman) 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
State ex rel. Michael Kelly v. Julie Inman, (Mo. 2020).

Opinion

SUPREME COURT OF MISSOURI en banc STATE ex rel. ) Opinion issued January 14, 2020 MICHAEL KELLY, ) ) Petitioner, ) ) v. ) No. SC97744 ) JULIE INMAN, ) ) Respondent. )

ORIGINAL PROCEEDING IN HABEAS CORPUS

Michael Kelly seeks a writ of habeas corpus on the ground his due process rights

were violated as a result of the circuit court exceeding its authority pursuant to section

552.020. 1 The circuit court accepted his not guilty by mental disease or defect (“NGRI”)

plea after finding he lacked competence to continue with the criminal proceedings. Kelly

argues that, pursuant to section 552.020.8, upon finding him incompetent, the circuit

court was required to suspend the proceedings and commit him to the department of

mental health.

1 All statutory references are to RSMo 1986, the law that governed at the time of Kelly’s criminal proceeding, unless otherwise specified. By accepting Kelly’s NGRI plea despite finding him incompetent to proceed, the

circuit court exceeded its authority pursuant to section 552.020.8 and violated Kelly’s due

process rights. Accordingly, Kelly’s NGRI plea is vacated, and the criminal proceedings

against him remain pending, although suspended by virtue of the circuit court’s

additional finding that Kelly was incompetent to proceed. Because of the improper

commitment after acceptance of Kelly’s NGRI plea, the department of mental health did

not conduct an examination of Kelly six months after his commitment to ascertain

whether he was fit to proceed, as required by section 552.020.10(1). Within 90 days

from the date the mandate issues in this case, the circuit court should order such an

examination to be conducted pursuant to section 552.020.11(1), RSMo Supp. 2018.

After the completion of the examination, the procedure in section 552.020.11, RSMo

Supp. 2018, should govern.

Background

The State charged Kelly with first-degree robbery and armed criminal action. The

defense moved for a mental evaluation of Kelly to determine his competency to proceed

to trial and whether he had a mental disease or defect excluding responsibility. The

circuit court sustained the motion. A medical evaluation found Kelly suffered from

chronic undifferentiated schizophrenia and polysubstance abuse or dependence. The

evaluation opined Kelly lacked the capacity to understand the proceedings or assist in his

own defense, and it recommended Kelly be held in a hospital facility for treatment

pending determination of his competency to proceed. It further concluded that, at the

2 time of the alleged criminal conduct, Kelly did not fully appreciate the nature, quality, or

wrongfulness of his conduct and was incapable of conforming his conduct to the law.

Kelly filed a notice of intent to rely solely on a defense of mental disease or

defect. The State accepted the defense. The circuit court entered an order titled “Order

Committing Defendant to Department of Mental Health (State Acceptance of Mental

Defense).” The order found Kelly lacked capacity to understand the proceedings against

him or assist in his own defense and, accordingly, lacked mental fitness to proceed with

the charges against him. In the same order, the circuit court found Kelly not guilty by

reason of mental disease or defect excluding responsibility, determining that, at the time

of the alleged crime, Kelly did not appreciate the nature, quality, or wrongfulness of his

conduct and was incapable of conforming his conduct to the requirements of the law.

The circuit court then committed Kelly to the department of mental health, where he has

remained since 1991.

Kelly filed petitions for writs of habeas corpus in the St. Francois County Circuit

Court and then the court of appeals, both of which were denied. Kelly now seeks a writ

of habeas corpus from this Court.

Jurisdiction and Standard of Review

This Court has jurisdiction to issue original remedial writs. Mo. Const. art. V, sec.

4.1. “Any person restrained of liberty within this state may petition for a writ of habeas

corpus to inquire into the cause of such restraint.” Rule 91.01(b); see also section

532.010, RSMo 2016. A court can issue a writ of habeas corpus when an individual is

“restrained of his or her liberty in violation of the constitution or laws of the state or

3 federal government.” State ex rel. Woodworth v. Denney, 396 S.W.3d 330, 337 (Mo.

banc 2013). The petitioner bears the burden to demonstrate he or she is entitled to habeas

relief. State ex rel. Clemons v. Larkins, 475 S.W.3d 60, 76 (Mo. banc 2015). “[H]abeas

corpus is available as a remedy for a person confined pursuant to Chapter 552 procedures

if an application therefor is properly pleaded, filed in a court having jurisdiction, and

facts are proven showing entitlement to relief.” State v. McKee, 39 S.W.3d 565, 569 n.6

(Mo. App. 2001).

Analysis

Kelly argues he is entitled to habeas relief on the ground the circuit court exceeded

its authority pursuant to section 552.020 when it accepted his NGRI plea and committed

him to the department of mental health after finding he lacked competence to proceed.

I. Is Kelly’s Claim Procedurally Barred?

The State asserts Kelly’s claim is procedurally barred because he did not raise it in

the circuit court at the time he made his NGRI plea or on direct appeal. Habeas relief is

not a substitute for direct appeal or postconviction proceedings. Denney, 396 S.W.3d at

337. Claims that were cognizable on direct appeal or in postconviction proceedings are

procedurally barred. Clay v. Dormire, 37 S.W.3d 214, 217 (Mo. banc 2000).

An appeal is proper “[i]n all cases of final judgment rendered upon any indictment

or information.” Section 547.070. “No right of an appeal exists without statutory

authority.” State v. Craig, 287 S.W.3d 676, 679 (Mo. banc 2009). There is no statutory

right to appeal from an acquittal as a result of an NGRI plea. State ex rel. Koster v.

Oxenhandler, 491 S.W.3d 576 (Mo. App. 2016) (“Habeas is thus the only viable means

4 by which the lawfulness of confinement as a result of the NGRI defense can be

challenged.” (emphasis added)). 2 Because the trial court acquitted Kelly as a result of an

NGRI plea, he could not have filed a direct appeal and habeas is the proper remedy in this

case.

Similarly, Kelly’s failure to raise his claim in the circuit court does not bar him

from habeas relief. The State cites State ex rel. Strong v. Griffith, 462 S.W.3d 732 (Mo.

banc 2015), in support of its argument that Kelly’s claim is procedurally barred for

failure to raise the claim in the circuit court, but that case can be distinguished on its

facts. The Court in Strong determined the claim was barred not only because it was not

raised at trial, but also because it was not raised during post-conviction proceedings. 462

S.W.3d at 734.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Jones v. United States
463 U.S. 354 (Supreme Court, 1983)
Medina v. California
505 U.S. 437 (Supreme Court, 1992)
Thompson v. Crawford
479 So. 2d 169 (District Court of Appeal of Florida, 1985)
State v. English
424 P.2d 601 (Supreme Court of Kansas, 1967)
State v. Jones
664 P.2d 1216 (Washington Supreme Court, 1983)
State Ex Rel. Amrine v. Roper
102 S.W.3d 541 (Supreme Court of Missouri, 2003)
Allen v. State
1998 OK CR 25 (Court of Criminal Appeals of Oklahoma, 1998)
State v. Craig
287 S.W.3d 676 (Supreme Court of Missouri, 2009)
Lodahl v. Papenberg
277 S.W.2d 548 (Supreme Court of Missouri, 1955)
State v. Walkup
220 S.W.3d 748 (Supreme Court of Missouri, 2007)
Commonwealth v. Harris
243 A.2d 408 (Supreme Court of Pennsylvania, 1968)
State v. Fassero
256 S.W.3d 109 (Supreme Court of Missouri, 2008)
Clay v. Dormire
37 S.W.3d 214 (Supreme Court of Missouri, 2000)
Jeans v. Jeans
314 S.W.2d 922 (Missouri Court of Appeals, 1958)
State v. Smith
564 P.2d 1154 (Washington Supreme Court, 1977)
State of Missouri v. Jesse Driskill
459 S.W.3d 412 (Supreme Court of Missouri, 2015)
State ex rel. Reginald Clemons v. Steve Larkins, Superintendent
475 S.W.3d 60 (Supreme Court of Missouri, 2015)
State v. McKee
39 S.W.3d 565 (Missouri Court of Appeals, 2001)

Cite This Page — Counsel Stack

Bluebook (online)
State ex rel. Michael Kelly v. Julie Inman, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-michael-kelly-v-julie-inman-mo-2020.