Muriel Jackson-Kuofie Missouri Cases

The State appealed the trial court's dismissal of a criminal complaint against Muriel Jackson-Kuofie with prejudice, which was based on the State's alleged failure to disclose a witness list prior to a preliminary hearing. The trial court found a violation of Rule 25.03(b)(2). The Western District reversed and remanded, holding that Rule 25.03(b)(2) applies only after an indictment or information is filed, not at the preliminary hearing stage when only a complaint has been filed. The court found the trial court's misapplication of the rule constituted plain error, resulting in manifest injustice.