Missouri Court of Appeals, Eastern District / Feb 22, 2022
State of Missouri, Appellant, vs. Jatonya S. Clayborn-Muldrow, Respondent.
The State of Missouri appealed the trial court's dismissal of a criminal information charging Jatonya S. Clayborn-Muldrow, a police officer, with attempted tampering with a victim. The trial court dismissed the charge, finding it was barred by the statute of limitations and factually insufficient. The appellate court affirmed the dismissal, holding that the one-year statute of limitations had run because the alleged criminal conduct occurred on March 15, 2020, and the information was filed on March 16, 2021. The court also found the alleged conduct on March 16, 2020, did not constitute an overt act of attempted tampering and declined to consider the public officer exception due to briefing deficiencies.