Supreme Court of Missouri

State of Missouri v. Jarrad Ryan Vandergrift

June 13, 2023

Summary

The Court held that the defendant timely invoked appellate jurisdiction because his right to appeal arose when the circuit court orally pronounced and imposed sentence in his presence, rather than when a written judgment was later entered. The delayed entry of a conforming written judgment did not divest jurisdiction, although the judgment had to be included in the appellate record. The Court also rejected the defendant's challenges to the denial of a new trial based on newly discovered evidence and to unobjected-to testimony concerning delayed disclosure of child sexual abuse.