State v. RohraAnnotate this Case
The Supreme Court affirmed the judgment of the circuit court convicting Defendant of unlawful possession of a firearm, holding that, by pleading guilty, Defendant waived his argument that the amended complaint and indictment charging him with unlawful possession of a firearm failed to allege the essential element of a prior “conviction.”
Defendant pleaded guilty to unlawful possession of a firearm, possession of marijuana, and possession of drug paraphernalia. The circuit court found Defendant’s plea was voluntary, there was a factual basis for the plea, and Defendant was guilty beyond a reasonable doubt. On appeal, Defendant argued that his Oklahoma deferred judgment did not qualify as a “conviction” pursuant to Mo. Rev. Stat. 571.070, and that this argument challenged the sufficiency of the charging documents and, therefore, was not barred by his guilty plea. The Supreme Court disagreed, holding that Defendant’s unconditional guilty plea waived his argument on appeal.