State v. Stufflebean
2017 WL 1496950, 516 S.W.3d 456, 2017 Mo. App. LEXIS 354 (2017)
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Rule of Law:
To convict a defendant for driving while suspended, the state must prove the defendant acted with criminal negligence regarding their knowledge of the suspension. A certified driving record alone is insufficient to prove this mental state when the suspension is for a non-driving, administrative reason, absent additional evidence that the defendant should have been aware of the risk of suspension.
Facts:
- Jason Stufflebean's driving privilege was reinstated on May 31, 2013.
- Stufflebean had a history of 22 prior convictions for driving while revoked or suspended, all related to point accumulation or insurance, with the last occurring in 2011.
- On October 4 and 5, 2014, Stufflebean's license was suspended for the first time for a new reason: "Child Support Enforcement Suspensions."
- On October 29, 2014, an off-duty police officer, Robby Ryan, observed Stufflebean driving a car.
- Officer Ryan recognized Stufflebean and, after having dispatch check, confirmed his license was suspended.
Procedural Posture:
- The State charged Jason Stufflebean in a Missouri trial court as a prior and persistent offender with felony driving while revoked or suspended.
- At a jury trial, the State presented the officer's testimony and a certified copy of Stufflebean's driving record.
- The jury found Stufflebean guilty.
- The trial court entered a judgment of conviction and sentenced Stufflebean to a term of three years' imprisonment.
- Stufflebean (appellant) appealed the judgment to the Missouri Court of Appeals, Eastern District, with the State as the appellee.
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Issue:
Is a certified driving record showing a license suspension for child support arrears, without any other evidence, sufficient to prove beyond a reasonable doubt that a defendant acted with criminal negligence with respect to the knowledge that his driving privileges were suspended?
Opinions:
Majority - Gaertner, Jr.
No. A certified driving record alone is not always sufficient evidence to prove a defendant was criminally negligent with respect to knowledge of their license suspension. To prove criminal negligence, the State must show the defendant failed to be aware of a substantial and unjustifiable risk, which constitutes a gross deviation from a reasonable person's standard of care. Unlike cases where a suspension results from an accumulation of points for driving offenses the defendant knows they committed, a suspension for a non-driving, administrative reason like child support delinquency requires additional evidence. Here, Stufflebean's license had been reinstated for over a year, he had no new driving offenses, and this was his first suspension for child support. The State provided no evidence that Stufflebean was notified of his child support delinquency or the resulting suspension. It is improper to simply infer that government agencies followed statutory notice requirements; the State must present some evidence, such as a copy of a notice letter, to establish the defendant should have been aware of the suspension.
Analysis:
This decision clarifies the evidentiary burden on the State in proving the 'mens rea' (mental state) for driving while suspended under Missouri law. It establishes a critical distinction between suspensions resulting from driving violations and those from administrative actions like child support enforcement. For the latter, the State cannot rely solely on the driving record but must produce some affirmative evidence suggesting the defendant's awareness of the risk of suspension. This ruling raises the bar for prosecutors and provides a defense for individuals who may genuinely be unaware of suspensions for non-driving reasons.
