Missouri Court of Appeals, Eastern District / May 30, 2023
State of Missouri, Appellant, v. Rachel Nixon, Respondent.
The State of Missouri appealed the trial court's judgment dismissing criminal charges against Rachel Nixon with prejudice, alleging discovery violations and a speedy trial violation. The trial court had found that the State made a willful or bad faith discovery violation by failing to produce an ATF report and that further delays would violate Nixon's right to a speedy trial. The appellate court reversed, holding that the State did not violate discovery rules because the ATF report was not subject to the trial court's jurisdiction under federal Touhy regulations, and therefore the speedy trial claim also failed.