Missouri Court of Appeals, Eastern District / Sep 26, 2023
Angela Brown appealed her conviction for possession of a controlled substance, arguing the circuit court erred in denying her motion to suppress and admitting her statements. However, Brown failed to appear for numerous sentencing and bond revocation hearings over a seven-month period, leading to the issuance of a capias warrant. The appellate court applied the escape rule, finding that Brown's deliberate disregard for court orders and the resulting delay adversely affected the criminal justice system. Consequently, Brown's appeal was dismissed.
Missouri Court of Appeals, Western District / Aug 3, 2021
Angela Brown sued VAALP for negligence after slipping on ice at an apartment complex. After her initial suit was dismissed without prejudice, Brown refiled and later sought to add VA Second LP as a defendant, believing it was the property owner, and subsequently dismissed VAALP. The trial court dismissed the claim against VA Second LP as time-barred, finding that the relation-back doctrine under Rule 55.33(c) did not apply. The appellate court affirmed, holding that adding a new defendant, even with a subsequent voluntary dismissal of an original defendant, does not constitute a substitution of parties for the purpose of the relation-back doctrine.