Judges: WILLIAM L. WEBSTER
Filed Date: 2/13/1987
Status: Precedential
Modified Date: 7/5/2016
Dear Mr. Icenogle:
This letter is in response to your question asking:
Does a plea of guilty to a felony under federal law (Title 18, Section 371 U.S.C.) followed by an order suspending imposition of sentence as to any penitentiary sentence and placing the defendant on probation, but imposing a fine and a community service requirement, constitute a conviction for purposes of forfeiture of elected office under Section
561.021 RSMo?
Section
1. A person holding any public office, elective or appointive, under the government of this state or any agency or political subdivision thereof, who is convicted of a crime shall forfeit such office if
(1) He is convicted under the laws of this state of a felony or under the laws of another jurisdiction of a crime which, if committed within this state, would be a felony; or
(2) He is convicted of a crime involving misconduct in office, or dishonesty; or
(3) The constitution or a statute other than the code so provides.
In State ex rel. Peach v. Tillman,
The statute in effect at the time the court suspended imposition of sentence granted the court power to suspend imposition of sentence and place the guilty person on probation. § 549.071 RSMo 1969. Nothing is said of the nature and consequences of the suspended imposition of sentence. Suspension of imposition of sentence is a hybrid in the law. It is a suspension of active proceedings in a criminal prosecution. It is not a final judgment. State v. Gordon,
344 S.W.2d 69 ,71 (Mo. 1961). Because there is no final judgment, there can be no appeal from such an order. See State v. Harris,486 S.W.2d 227 (Mo. 1972). It has been held that it is not a conviction within the meaning of the Second Offender Act § 556.280 RSMo 1969, State v. Gordon, supra, nor can it be used to impeach a witness under §491.050 RSMo 1978. State v. Frey,459 S.W.2d 359 (Mo. 1970).As stated in other jurisdictions, suspension of imposition of sentence is a matter of "grace, favor and forebearance." Pagano v. Bechly,
211 Iowa 1294 ,1298 ,232 N.W. 798 ,800 (1930). Suspension of imposition of sentence is a salutary means of relieving a person who is guilty of a crime from the stigma of a conviction when the court in its discretion feels that the ends of justice warrant the court's forebearance.
The Missouri legislature amended various statutes to take into account situations in addition to "convictions". Section
The Missouri Supreme Court considered suspended imposition of sentence in State v. Lynch,
Review of federal law and statutes, however, results in a different conclusion. The federal statute pertaining to suspended imposition of sentence and probation,
Upon entering a judgment of conviction of any offense not punishable by death or life imprisonment, any court having jurisdiction to try offenses against the United States when satisfied that the ends of justice and the best interest of the public as well as the defendant will be served thereby, may suspend the imposition or execution of sentence and place the defendant on probation for such period and upon such terms and conditions as the court deems best.
(Emphasis added.)
The federal rule is that a suspended or probated sentence is regarded as having the same effect as any other final judgment or conviction. Davis v. Estelle,
Section
Also relevant to construction of this particular statute is the legislative intent that may be gleaned from other statutes. As discussed previously, the legislature amended the extended term provisions, Section
Finally, this issue has been addressed by a Missouri court in an analogous situation. In Warren v. Director, MissouriDivision of Health,
The reasoning in Warren is equally applicable to the issue presented by the instant facts. The situation presented here involves the question of collateral loss of a valuable privilege, i.e., privilege of holding a public office. It follows that since a suspended imposition of sentence by a Missouri court would not be considered a conviction under Section
Very truly yours,
WILLIAM L. WEBSTER Attorney General
Pagano v. Bechly , 211 Iowa 1294 ( 1930 )
State v. Frey , 1970 Mo. LEXIS 853 ( 1970 )
State v. Lynch , 1984 Mo. LEXIS 305 ( 1984 )
David A. Davis v. W. J. Estelle, Director, Texas Department ... , 502 F.2d 523 ( 1974 )
United States v. Rosenstengel , 323 F. Supp. 499 ( 1971 )
State v. Gordon , 1961 Mo. LEXIS 713 ( 1961 )
State Ex Rel. Peach v. Tillman , 1981 Mo. App. LEXIS 3627 ( 1981 )
Collins v. Director of Revenue , 1985 Mo. LEXIS 257 ( 1985 )
State v. Sweeney , 1985 Mo. LEXIS 294 ( 1985 )