Missouri Court of Appeals, Eastern District / Dec 28, 2021
State of Missouri, Appellant, vs. Joseph E. Vaughn, Respondent.
The State of Missouri appealed the circuit court's dismissal of criminal charges against Joseph E. Vaughn, who was found unconscious with drug paraphernalia. The circuit court dismissed the charges, finding that Missouri's "Good Samaritan Law," § 195.205, applied to prohibit prosecution. The State argued that § 195.205 "effectively amended" the possession statutes, and thus § 1.160 should bar its retroactive application. The appellate court affirmed the dismissal, holding that § 195.205 is a new statutory provision and not an amendment, so § 1.160 does not apply.