State of Missouri, ex rel. Eric S. Schmitt Missouri Cases

The State of Missouri sought a writ of certiorari to review the Cole County Circuit Court's grant of habeas corpus relief, which vacated Jonathan H. Irons's convictions for first-degree assault, armed criminal action, and first-degree burglary. The habeas court found a Brady violation based on the State's suppression of a latent fingerprint report. The appellate court affirmed the habeas court's judgment, holding that the Brady claim was not procedurally defaulted under the cause and prejudice exception and that sufficient evidence established the Brady violation. As a result, Irons's convictions remain vacated, and the State must announce its intention to retry him within ten days or he will be discharged.

Vance A. Cole's probation was revoked after his earned compliance credits (ECC) should have led to its expiration. The habeas court granted Cole's petition, ordering his release from confinement, discharge from probation, and relief from sentence execution. The Attorney General sought a writ of certiorari, arguing Cole invited the error and that ECC challenges are not cognizable in habeas. The appellate court refused to quash the habeas court's record, holding that Cole did not invite the error and that the constitutional right to habeas corpus cannot be statutorily circumscribed, thus allowing review of the ECC issue.