Supreme Court of Missouri / Apr 30, 2024
State of Missouri, Appellant, vs. Ashley Colville, Respondent.
Ashley Colville was charged with second-degree involuntary manslaughter after a fatal motor vehicle accident. The circuit court dismissed the indictment with prejudice, finding that Colville's alleged actions did not amount to criminal negligence after reviewing a surveillance video. The State appealed, arguing the circuit court improperly considered evidence outside the indictment. The Missouri Supreme Court vacated the circuit court's judgment and remanded the case, holding that a court's review of an indictment at the motion to dismiss stage is limited to the face of the indictment to determine if it states the essential elements and apprises the defendant of the facts.