Supreme Court of Missouri / Dec 18, 2018
State of Missouri, Respondent, vs. Edward Hughes, Appellant.
Edward Hughes appealed the circuit court's denial of his motion to suppress drugs and drug paraphernalia found in his bag during a warrantless search incident to arrest, arguing the search violated Arizona v. Gant and State v. Carrawell. The Missouri Supreme Court affirmed the circuit court's judgment. The Court found it unnecessary to reach the Fourth Amendment issue, holding that any error in denying the motion to suppress was not prejudicial because sufficient additional evidence, including defense counsel's cross-examination and stipulation to lab reports, supported the conviction.