Missouri Court of Appeals, Western District / Mar 26, 2024
Rachel Lynn Sanning vs. Director of Revenue, State of Missouri
Rachel Lynn Sanning appealed the suspension of her Missouri driver's license by the Director of Revenue, which was based on an alleged driving while intoxicated conviction in Germany. The trial court sustained the suspension, finding Sanning's challenge to be an impermissible collateral attack and the Provost Marshal's letter sufficient evidence of a conviction. The appellate court reversed, holding that the Director failed to present substantial evidence of a conviction because the Provost Marshal's letter did not identify a court of conviction or explicitly state a criminal conviction occurred, and Sanning's challenge was not an impermissible collateral attack.