Missouri State Highway Patrol Criminal Records Repository Missouri Cases

L.F.A. sought removal from the Missouri sex offender registry, which the circuit court granted. The Missouri State Highway Patrol appealed this judgment. During the pendency of the appeal, a separate circuit court judgment in another case involving L.F.A. determined he was barred from removal from the registry. The appellate court reversed the initial judgment and remanded with instructions to deny L.F.A.'s petition, concluding that the unappealed subsequent judgment precluded his removal, consistent with the Missouri Supreme Court's ruling in *Smith v. St. Louis County Police*.

J.C.S. filed a petition seeking removal from the Missouri Sex Offender Registry, which the trial court granted after a hearing. The Missouri State Highway Patrol Criminal Records Repository (MSHP) appealed, arguing the trial court failed to determine if J.C.S. was required to register under federal law, which would impose a lifetime registration obligation. The appellate court reversed the trial court's judgment and remanded the case, holding that it could not review the judgment due to an incomplete record on appeal, as no record was made of the trial court hearing.

N.M.C. sought to expunge multiple criminal records, including two felony offenses from 2006 and 2013, under section 610.140 RSMo. The trial court granted the expungement of both felonies. The Missouri State Highway Patrol Criminal Records Repository appealed, arguing that the statute limits expungement to one felony offense per lifetime. The appellate court reversed and remanded, holding that the Highway Patrol had standing, the issue was preserved, and the trial court erred by expunging more than one felony record, as the 2006 and 2013 offenses were not part of the same indictment, information, or course of criminal conduct.