ST. LOUIS — A man convicted for felony driving on a suspended license has had his conviction overturned by the Missouri Court of Appeals, Eastern District.
In an opinion issued on April 25, the court found that the state failed to produce sufficient evidence of Jason Stufflebean's mental state to warrant his Warren County conviction in Judge Michael Wright's court.
"We must reverse,"Judge Gary Gaertner Jr. wrote for the majority. Judges James Dowd and Kurt Odenwald concurred.
"This case turns on how much evidence the State must produce in order to prove that a defendant is criminally negligent with respect to knowledge that the State had revoked or suspended his or her driving privileges," Gaertner wrote."While criminal negligence is a very low standard, this standard still requires the State to produce some evidence of a defendant's mental state to convict a defendant of driving while revoked or suspended."
The incident that formed the basis of the state's prosecution of Stufflebean happened on Oct. 29, 2014, when he was spotted by an off-duty Warren County police officer who thought his license was suspended. The officer initiated a process that ultimately led to the arrest, according to background information provided in the opinion.
At trial, Stufflebean was charged as a "prior and persistent" offender with one count of driving while revoked or suspended, which is a class D felony based on his prior convictions for driving while revoked or suspended.
Also at trial, his driving record was produced, which included two Missouri Department of Revenue child support enforcement suspensions effective Oct. 4, 2014, and Oct. 5, 2014.
On appeal, Stufflebean argued that the only evidence of his suspension was his driving record, but that there was no evidence produced at trial that he had knowledge that his license had been suspended and that he acted with criminal negligence "with respect to the knowledge of the fact that the Department of Revenue had suspended his driving privileges," the opinion states.
"We agree," the court concluded.