State v. Jacobs, 421 S.W.3d 507

Defendant (Victor Allen Jacobs) was a registered sex offender for a 2001 rape conviction and had updated registrations after release; he last registered with the Greene County registrar on March 7, 2011.
On May 24, 2011, Defendant asked the county registrar whether he could live at 666 S. Jefferson; the registrar told him the address was too close to a school and refused to approve it.
Defendant later moved from his listed 805 E. Dale address about two to two-and-a-half months before August 9, 2011, but did not timely update his registration; he admitted to Sgt. Walker on August 9 that he had moved earlier and had lied to the registrar about his address.
Defendant completed a change-of-address registration on August 10, 2011, listing 666 S. Jefferson, Apt. 5.
He was charged, waived a jury, was tried by the court, found guilty of failing to register as a sex offender, and sentenced to four years. The trial court entered judgment before the 15-day period to file a motion for new trial had expired and without an express written waiver.

Issue	State's Argument	Defendant's Argument	Held
Whether the judgment was void or appeal must be dismissed because the court entered judgment/sentence before the 15-day motion-for-new-trial period expired and without an express waiver	The timing error is procedural only; circuit court had subject-matter and personal jurisdiction, so the judgment is not void and any timing error can be waived	Judgment is void (premature) absent an express waiver; appeal should be dismissed per precedent	Court held J.C.W. controls: timing rule is procedural; the judgment was not void and any error was waived, so appellate jurisdiction exists to reach merits
Whether evidence was sufficient to prove failure to register (elements: registration duty, change of residence, failure to inform within 3 days, knowing conduct)	Certified conviction proved registration duty; Defendant’s August admission showed he changed residence and failed to notify within 3 days; his prior compliance, knowledge of duty, and false statements support a knowing mental state	Defendant says he reported the May move to the registrar (registrar refused to accept), so he did not knowingly fail to register	Court held evidence sufficient on all elements: duty, change, failure to timely report, and knowing conduct; conviction affirmed

J.C.W. ex rel. Webb v. Wyciskalla, 275 S.W.3d 249 (Mo. banc 2009) (procedural statutory errors do not deprive trial court of subject-matter jurisdiction)
Besendorfer v. State, 372 S.W.3d 914 (Mo. App. W.D. 2012) (holding judgment premature and void when entered before new-trial period expired)
Wren v. State, 609 S.W.2d 480 (Mo. App. W.D. 1980) (early precedent treating premature judgments as causing dismissal of appeal)
State v. Perry, 275 S.W.3d 237 (Mo. banc 2009) (false or inconsistent statements can show consciousness of guilt)
State v. Kelly, 367 S.W.3d 629 (Mo. App. E.D. 2012) (standard of review for sufficiency challenges)
Jaeger v. State, 394 S.W.2d 347 (Mo. 1965) (distinguishing instances where sentencing proclamation was not final sentence)