State v. Prince, 518 S.W.3d 847

Background

In 2005–2007, Prince’s daughter (Victim) suffered acute and chronic malnutrition and developmental regression; medical staff concluded food was intentionally withheld and reported abuse. Children’s Division removed Victim; she improved in foster care but was returned to Prince in April 2007.
After return, Victim was repeatedly confined to a locked upstairs closet, often deprived of regular food and hygiene, and forced to soil herself; Prince admitted locking Victim as punishment.
A 2012 hotline report, neighbor statements, and housing records prompted police to enter Prince’s apartment without a warrant; officers found Victim in a tied closet and took her to the hospital.
Prince was arrested and charged with first-degree assault, felony child abuse, and first-degree endangering the welfare of a child. She initially entered Alford pleas and a conventional plea under a plea agreement, then sent a postcard and a public letter claiming coercion; the plea court set aside the pleas.
The case proceeded to jury trial (Prince did not renew suppression objections at trial); she was convicted on all counts and sentenced to consecutive prison terms totaling 34 years. Prince appealed.

Issues

Issue	Prince's Argument	State's Argument	Held
Whether plea court erred in vacating Prince’s Alford/conventional pleas and thereby violated due process/double jeopardy	Vacatur was improper because pleas had been accepted and jeopardy attached; plea court acted sua sponte	Prince herself raised voluntariness by mailing a postcard and public letter claiming coercion; court permissibly treated communication as a withdrawal request and investigated voluntariness	No plain error: court properly set aside pleas after defendant claimed they were involuntary; Creamer is distinguishable because here defendant alleged coercion (not mere continued assertion of innocence)
Whether warrantless entry into apartment and seizure of Victim violated Fourth Amendment (motion to suppress)	Entry was unlawful; no immediate exigency justified bypassing a warrant	Hotline call, neighbor corroboration, housing records, and prior abuse history gave officers reasonable basis to believe Victim was in the apartment and in danger; exigent-circumstances exception applies	No plain error: exigent circumstances justified warrantless entry to render aid and prevent ongoing harm
Whether trial court abused discretion in denying mistrial after Prince’s courtroom outburst during victim-impact testimony	Outburst and witness’s statements were prejudicial; mistrial necessary	Outburst was provoked by defendant’s own conduct; court gave curative instructions and admonished State; jury presumed to follow instructions	No abuse of discretion: mistrial not required; curative instruction and reprimand were adequate remedies

Key Cases Cited

State v. Taylor, 466 S.W.3d 521 (Mo. banc 2015) (plain-error standard for unpreserved appellate claims)
State v. Creamer, 161 S.W.3d 420 (Mo. App. W.D. 2005) (trial court erred withdrawing Alford plea where defendant merely maintained innocence)
State v. Douglas, 622 S.W.2d 28 (Mo. App. W.D. 1981) (trial court may set aside previously accepted plea when voluntariness is credibly challenged)
State v. Burnett, 230 S.W.3d 15 (Mo. App. W.D. 2007) (warrantless entry justified by exigent circumstances where a child’s safety was at risk)
State v. Oliver, 293 S.W.3d 437 (Mo. banc 2009) (warrantless home entries presumptively unreasonable; exigent-circumstances exceptions apply)
North Carolina v. Alford, 400 U.S. 25 (U.S. 1970) (Alford plea permits guilty plea without express admission of guilt)