Biography of Missouri DWI Attorney Carl M. Ward

Carl M. Ward was born in 1957. In 1981, he received his undergraduate degree from the University of Missouri, where he graduated with the school's highest honors (Summa Cum Laude). In 1984, he graduated from St. Louis University School of Law, where he received his J.D. degree. He was admitted to the Missouri Bar that year, and has been an attorney in private practice since that time. Nearly all of his practice is devoted to the representation of citizens accused of driving while intoxicated.

Mr. Ward is a regular speaker at Missouri DWI defense seminars, and has chaired or moderated the state's largest DWI defense programs for attorneys since 1997. He has lectured to more than 1000 attorneys, judges and police officers from around the State of Missouri and elsewhere. He has attended numerous DWI defense programs around the country and he is well known for his innovative and aggressive defense of his clients. Carl is one of only a few attorneys in the State of Missouri who has attained the level of field sobriety testing instructor through a NHTSA/IACP approved training program. He traveled to Mansfield, Ohio, where he received advanced factory training as a maintenance supervisor on the BAC Datamaster, the primary breath testing machine used in Missouri. He is an owner of a BAC Datamaster, an Intoxilyzer 5000, and a portable breath test ("PBT") machine.

Carl has represented hundreds of drivers accused of drunk driving in over 170 municipal, county and state courts across Missouri. He has argued DWI related issues before the Eastern, Western, and Southern District Courts of Appeals as well as the Missouri Supreme Court. He has been quoted in the St. Louis Daily Record, Columbia Tribune, and Missouri Lawyers Weekly. Mr. Ward's case, Brown v. Director of Revenue, 85 S.W.3d 1 (Mo. 2002), made the Missouri Lawyers Weekly's list of Top Cases for 2002. There, the Missouri Supreme Court held, in part, that a trial court judge may disregard the results of improperly administered field sobriety tests when determining whether or not a police officer has probable cause to arrest a motorist for driving while intoxicated, an issue in every administrative license suspension or revocation case in Missouri.

Mr. Ward is a member of the National College for DUI Defense, the Missouri Bar Association, and the Missouri Association of Criminal Defense Lawyers. As a result of an extensive and confidential peer review by attorneys and judges from around the state, he has been awarded an "AV" rating of excellence in Martindale-Hubbell. His hobbies include Civil War history and reenactment, genealogy, and attending auto racing events with his father.

He has previously served as an in-service instructor for the Chesterfield Police Department,one of the largest municipal police departments in the State of Missouri, where he taught DWI law and SFST administration.

Carl Ward's Professional Speaking Engagements

March 22, 1996 - Defending Your Client in a DWI Case. Sponsored by the University of Missouri-Columbia School of Law. Held at: The Adam's Mark Hotel. St. Louis, Missouri. Speaker: "Successful Strategies in Defending a DWI Case."

June 20, 1997 - A Practical Approach to DWI Defense. Sponsored by the University of Missouri-Columbia School of Law. Held at: The Ritz-Carlton, Clayton, Missouri. Served as Program Moderator; Speaker: "Field Sobriety Testing and Practical Tips on Dealing With the Testimony of the Arresting Officer."

June 12, 1998 - Getting Tough on DWI - The Defense. Sponsored by the University of Missouri Columbia School of Law. Held at: The Marriott-West Hotel, Town & Country, Missouri. Served as Program Chair; Speaker: "Field Sobriety Testing and Dealing with the Testimony of the Arresting Officer."

May 7, 1999 - 4th Annual DWI Defense Institute - Defending the Drinking Driver. Sponsored by the University of Missouri-Columbia School of Law. Held at: Marriott Tan-Tar-A, Lake Ozark, Missouri. Served as Program Chair; Speaker: "What Happened to the Bill of Rights and the Rules of Evidence in Department of Revenue Cases?"

October 6-7, 2000 - 5th Annual DWI Defense Institute - Defending the Drinking Driver. Sponsored by the University of Missouri-Columbia School of Law. Held at: The Ritz-Carlton, Clayton, Missouri. Served as Program Chair; Speaker: "Standardized Field Sobriety Testing."

October 19, 2001 - Missouri Association of Criminal Defense Lawyers - Fall Seminar. Held at: Arrowhead Club, Kansas City, Missouri. Speaker: "DWI Law."

April 12-13, 2002 - Missouri Association of Criminal Defense Lawyers - Spring Seminar. Held at: Harrah's Kansas City Hotel, Casino and Conference Center. Speaker: "DWI - Cross Examination on Field Sobriety Tests."

May 10-11, 2002 - 6th Annual DWI Defense Institute - Defending the Drinking Driver: Anatomy of a Felony DWI Trial. Sponsored by the University of Missouri-Columbia School of Law. Held at: UM-Columbia's Law School, Columbia, Missouri. Served as Program Chair; Speaker: "Standardized Field Sobriety Testing."

August 5, 2002 - The 2002 Missouri Judicial College. Held at: Lodge of the Four Seasons, Lake Ozark, Missouri. Sponsored by the Missouri Trial Judge Education Committee. Served as a Faculty Member and Speaker: "Department of Revenue Cases."

October 28, 2002 - The 2002 Missouri Judicial College. Held at: Fairmont Hotel, Kansas City, Missouri. Sponsored by the Missouri Trial Judge Education Committee. Served as a Faculty Member and Speaker: "Department of Revenue Cases."

June 6, 2003 - Defending the Accused Driver: Intoxication by Alcohol or Drugs and Felony Driving Charges. Sponsored by The Missouri Bar. Held at: Doubletree Hotel, Kansas City, Missouri. Program Co-Chairman; Speaker: "Standardized Field Sobriety Testing."

June 27, 2003 - Defending the Accused Driver: Intoxication by Alcohol or Drugs and Felony Driving Charges. Sponsored by The Missouri Bar. Held at: Clayton, Missouri. Program Co-Chairman; Speaker: "Standardized Field Sobriety Testing."

February 20, 2004 - Strategies in Handling DWI Cases in Missouri. Sponsored by Lorman Education Services. Holiday Inn Westport, St. Louis, Mo. Speaker: "Standardized Field Sobriety Testing."

April 23, 2004 - Defending the DWI Case. Sponsored by Missouri Public Defenders Association. Held at: Adam’s Mark Hotel, Kansas City, Missouri. Speaker: "Attacking Field Sobriety, Breath and Blood Tests."

June 24, 2004 - Defending the Accused Driver: DWI and DOR Cases. Sponsored by The Missouri Bar. Held at: Westin Crowne Center, Kansas City, Missouri. Program Co-Chairman; Speaker: "Field Sobriety Testing."

June 25, 2004 - Defending the Accused Driver: DWI and DOR Cases. Sponsored by The Missouri Bar. Held at: Ritz-Carlton, Clayton, Missouri. Program Co-Chairman; Speaker: "Field Sobriety Testing."

June 24, 2005 - Demystifying the DWI Process: The Nuts and Bolts. Sponsored by The Missouri Bar and the Missouri Association of Criminal Defense Lawyers. Held at: Washington University School of Law, St. Louis, Missouri. Program Co-Moderator; Speaker: "Challenging the Administrative Suspension and Chemical Refusal Revocation."

July 28-29, 2006 - DWI Defense Seminar. Sponsored by The Missouri Bar and the Missouri Association of Criminal Defense Lawyers. Held at: Lodge of the Four Seasons, Lake Ozark, Missouri. Program Co-Moderator; Speaker: "Winning Moves in a DOR case."

October 6, 2006 - Defending Your Client’s Driver’s License Following A DWI Arrest. Program producer and sole presenter. Held at: The Crowne Plaza Hotel, Clayton, Missouri.

November 10, 2006 - Defending Your Client’s Driver’s License Following A DWI Arrest. Program producer and sole presenter. Held at: The Days Inn Conference Center, Columbia, Missouri.

December 12, 2006 - Missouri State Public Defender’s Conference. Held at St. Louis, Missouri. Speaker: “Blood and Breath Testing.”

March 30, 2007 - Defending Your Client’s Driver’s License Following A DWI Arrest. Program producer and sole presenter. Held at: The Crowne Plaza Hotel, Clayton, Missouri.

June 9, 2007 - Solo and Small Firm Conference. Sponsored by The Missouri Bar. Held at: Tan-Tar-a Resort, Osage Beach, Missouri. Speaker: “ Saturday Morning Hangover - The Headaches of Representing a Client with a DWI case.”

July 27-28, 2007 - DWI / DUI Defense Seminar. Sponsored by The Missouri Bar and the Missouri Association of Criminal Defense Lawyers. Held at: Lodge of the Four Seasons, Lake Ozark, Missouri. Defending a DWI case.

September 11, 2007 - How to Series: DWI/DUI. Sponsored by the Missouri Bar. Interactive telephone seminar. Speaker: Nuts and Bolts of Administrative DWI License Suspension Cases.

September 29, 2007 - District VII Justice Phi Alpha Delta Law Fraternity International meeting. Held at: American Bounty, Washington, Missouri.

Upcoming Speaking Engagements

April 18, 2008 - Missouri Association of Criminal Defense Lawyers - Spring Seminar. To be Held at: Branson, Missouri. Speaker: "DWI Law."

May 3, 2008 - National Association of Legal Secretaries Annual Meeting. St. Louis, Missouri. "CDL and Abuse and Lose Law in Missouri."

July 25-26, 2008 - DWI / DUI Defense Seminar. Sponsored by The Missouri Bar and the Missouri Association of Criminal Defense Lawyers. To be held at: Lodge of the Four Seasons, Lake Ozark, Missouri. Mock DWI Jury Trial

Police Training Courses Taught

January 16, 2004 - DWI & SFST Training. Conducted by Carl Ward at Chesterfield Police Department.

January 23, 2004 - DWI & SFST Training. Conducted by Carl Ward at Chesterfield Police Department.

January 26, 2004 - DWI & SFST Training. Conducted by Carl Ward at Chesterfield Police Department.

January 29, 2004 - DWI & SFST Training. Conducted by Carl Ward at Chesterfield Police Department.

February 6, 2004 - DWI & SFST Training. Conducted by Carl Ward at Chesterfield Police Department.

February 9, 2004 - DWI & SFST Training. Conducted by Carl Ward at Chesterfield Police Department.

March 10, 2006 - DWI & SFST Training. Conducted by Carl Ward at Washington Police Department.

March 15, 2006 - Guest Speaker. Basic SFST Training Program. Creve Couer Community Center.

March 17, 2006 - DWI & SFST Training. Conducted by Carl Ward at Washington Police Department.

June 15, 2006 - Guest Speaker. Basic SFST Training Program. Jefferson College Police Academy.

August 9, 2006 - Guest Speaker. Basic 24 hour SFST Training Program. Overland Community Center.

September 20, 2006 - Guest Speaker. Basic 24 hour SFST Training Program. Creve Coeur Community Center.

January 31, 2007 - Guest Speaker. Basic 24 hour SFST Training Program. St. Louis County Police and Fire Training Center.

March 13-16, 2007. Instructor/Speaker. Basic 24 hour SFST Training Program. Washington, Missouri Public Safety Building, Washington, Missouri.

August 24, 2007 - Guest Speaker. Basic 24 hour SFST Training Program. Ballwin Police Department.

August 30, 2007 - Guest Speaker. Basic 24 hour SFST Training Program. St. Louis County Police and Fire Training Center.

September 20, 2007 - Guest Speaker. Basic 24 hour SFST Training Program. St. Louis County Police and Fire Training Center.

March 19, 2008 - Guest Speaker.  Basic 24 hour SFST Training Program.  Kirksville, Missouri

April 1, 2008 - Guest Speaker, Basic 24 hour SFST Training Program, Kirksville, Missouri

Advanced DWI Related Training Programs Attended

1999 - NHTSA/IACP Standardized Field Sobriety Testing Student Training Course. Atlanta, Georgia.

June 15-17, 2000 - NHTSA/IACP Standardized Field Sobriety Testing Instructor Course. Nashville, Tennessee.

August 14-16, 2003 - National Patent Analytical Systems, Inc. - BAC Datamaster (Operator/Supervisor) Training Course. Held at: NPAS plant, Mansfield, Ohio.

June 19, 2004 - - NHTSA/IACP Standardized Field Sobriety Testing Instructor Update Course. Nashville, Tennessee.

February 18-19, 2006 - NHTSA/IACP Standardized Field Sobriety Testing Student and Instructor Update Course. Las Vegas, Nevada.

Other DWI-Related Seminars Attended

February 12-13, 1993 - Getting Tough on DWI: The Defense - 8th Annual Seminar. Sponsored by: The Minnesota Society for Criminal Justice. Las Vegas, Nevada.

February 2-4, 1995 - Getting Tough on DWI - 10th National Seminar. Sponsored by: The Minnesota Society for Criminal Justice. Las Vegas, Nevada.

February 21-22, 1997 -Getting Tough on DWI - 12th National Seminar. Sponsored by: The Minnesota Society for Criminal Justice. Las Vegas, Nevada.

February 13-14, 1998 -Getting Tough on DWI - 13th National Seminar. Sponsored by: The Minnesota Society for Criminal Justice. New Orleans, La.

February 11-13, 1999 - Getting Tough on DWI: The Defense: Science on Trial - 14th National Seminar. Sponsored by: The Minnesota Society for Criminal Justice. Las Vegas, Nevada.

December 3, 1999 - National College for DUI Defense - 1999 Winter Session. Kansas City, Missouri.

February 16-17, 2000 - Getting Tough on DWI: The Defense - 15th National Seminar. Sponsored by: The Minnesota Society for Criminal Justice. Las Vegas, Nevada.

April 7-8, 2000 - Mastering Scientific Evidence in DUI/DWI Cases. Sponsored by the National College for DUI Defense. Atlanta, Georgia.

February 15-17, 2001 - Getting Tough on DWI: The Defense - 16th National Seminar. Sponsored by: The Minnesota Society for Criminal Justice. Las Vegas, Nevada.

October 3-5, 2002 - DWI Means Defend With Ingenuity. Sponsored by the National Association of Criminal Defense Lawyers and the National College for DUI Defense. Las Vegas, Nevada.

October 14-16, 2004 - Presenting a Gold Medal Defense. Sponsored by National Association of Criminal Defense Lawyers. Las Vegas, Nevada.

April 19-21, 2007 - Mastering Scientific Evidence in DUI / DWI Cases. Sponsored by the Texas Criminal Defense Lawyers Association and the National College for DUI Defense. Dallas, Texas.

Carl Ward’s Important Missouri Supreme Court and Missouri Court of Appeals Cases

Brown v. Director of Revenue, 85 S.W. 3d 1 (Mo. 2002). In Missouri, if a driver is arrested for driving while intoxicated and then tests over the legal limit, the Director of Revenue will suspend or revoke the driving privileges of that individual unless a hearing is requested within 15 days of the date of arrest. At the hearing, the administrative hearing officer will determine: (1) if there was "probable cause" to believe the person arrested was driving while intoxicated; and (2) if the driver’s blood alcohol exceeded the legal limit. If the hearing officer rules against the driver, the driver may appeal the decision of the administrative hearing officer and obtain a "trial de novo" in the circuit court, where the court will determine these issues anew. Similarly, if a driver refuses a breath test, and files a petition for review in the Circuit Court, one of the issues in the case will be whether or not there was reasonable grounds to believe the driver was intoxicated at the time of the arrest. In the Brown case, for the first time, the Missouri Supreme Court held that when determining whether or not there is probable cause to arrest a driver for DWI, a hearing officer or trial court judge may disregard a police officer’s testimony concerning the results of improperly administered standardized field sobriety tests. The rationale behind this rule is that probable cause determinations are made from vantage point of a reasonably prudent, cautious, trained police officer. Such officers know how to properly administer, interpret and score field sobriety tests, and would not rely upon the results of improperly administered tests when making a probable cause determination.

Dabin v. Director of Revenue, 9 S.W.3d 610 (Mo. 2000). Here, the Supreme Court of Missouri recognized that drivers have a constitutionally protected property interest in their drivers licenses which cannot be taken by the government without procedural due process. Although, in St. Louis County, "traffic court commissioners" are authorized by state statute to hear trial de novo cases, and to make recommendations to the circuit court, the Supreme Court found that Dabin was denied due process because neither the statute nor local court rule contained any provision for review of the traffic court commissioner’s "recommendation" before it became a final judgment. Now, a motorist who is dissatisfied with the "recommendation" of a traffic court commissioner in St. Louis County has 20 days to file a motion for rehearing or new trial with one of the circuit court judges and to challenge the traffic commissioner's findings as part of the trial de novo process. After arguments, the circuit court may (a) accept the commissioner’s findings; (b) reject the commissioner’s findings and enter judgment for the driver; or (c) reject the commissioner’s findings and grant the driver a new trial before a circuit court judge.

Paty v. Director of Revenue, 168 S.W.3d 625 (Mo. App. E.D. 2005). For the first time, the Eastern District Court of Appeals acknowledged that a trial court may disregard the testimony of a police officer concerning the results of improperly administered field sobriety tests when making a probable cause determination. The court determined that this rule also applicable to an improperly administered portable breath test ("PBT"). Here, the trial court found that the trooper who administered the portable breath test to Paty did not properly administer the test. He did not observe Paty for 15-20 minutes as required, had no formal training to operate the device, and the device had not been checked for calibration since it had been purchased. The Eastern District Court of Appeals held that because the reliability of field sobriety tests is a factual issue, an appellate court must give deference to the determinations made by the trial court. The trial court’s decision setting aside Paty’s license revocation was upheld by the Court of Appeals.

York v. Director of Revenue, 186 S.W.3d 267 (Mo.2006) . In this case, the only evidence which could arguably support the trooper’s decision to arrest the petitioner was the results of a portable breath test which was administered only 3 minutes after York was stopped at a DUI checkpoint. The trial court had found that all of the other field sobriety tests had been improperly administered and excluded them from consideration. The Director was unable to establish that York had any problems with his balance or speech prior to arrest. The trooper admitted that she was required to observe York for 15-20 minutes before administering the PBT test, that she did not do so, and that she should not have relied upon the results of the PBT when making a probable cause determination. The trial court refused to admit the PBT test into evidence under the circumstances of this case and ruled in favor of the driver. The Southern District Court of Appeals determined that in the absence of the PBT, there wasn’t probable cause to arrest the petitioner. However, because a Missouri statute provided for the admission of PBT evidence for probable cause determinations, the decision of the trial court was reversed and the case was remanded for a new trial. Mr. Ward then filed a motion for transfer with the Supreme Court of Missouri, which was granted.

The Missouri Supreme Court disagreed with the Southern District Court of Appeals, and affirmed the trial court’s decision in favor of York. The Supreme Court determined that even though a statute makes the PBT result admissible for probable cause purposes, it is up to the trial court to determine what weight to give to the evidence. Here, the trial court made an alternative finding to the effect that even if the PBT result had been admitted, it would have given the Trooper’s testimony no weight because of improper maintenance, training and use of the device by the Trooper. As a result, the Supreme Court determined that the trial court’s ruling on the admissibility of the PBT was not prejudicial, and was harmless. The court also determined that even though there was uncontroverted evidence that York had bloodshot, watery, glassy eyes, the smell of alcohol on his breath, and admitted to drinking one or two beers, the trial court was still free to conclude from these facts that probable cause to arrest was lacking.

Duncan v. Dir. of Revenue, 164 S.W.3d 88 (Mo. App. E.D. 2005). Held, that where a trial court has made a specific finding that it did not believe the testimony of the Director's witness, in this case, the arresting officer, the Court of Appeals must defer to the trial court's credibility determination, even if police officer’s testimony is uncontroverted by the driver or other witnesses.

Reece v. Dir. of Revenue, 61 S.W.3d 288 (Mo. App. E.D. 2001). In this case, Reece was arrested and charged with driving while intoxicated. He allegedly refused to submit to a breath test. Reece filed a petition for review with the Circuit Court. The police officer did not appear at trial and the Director of Revenue offered Reece’s arrest report into evidence to try to make a prima facie case. The arresting officer had written in his report in more than one place that Reece refused the breath test. However, he had also completed the breath test checklist and breath test certification sections of the arrest report. The checklist, which was completed by the arresting officer, provided that:

"1. Subject observed for at least 15 minutes by Officer Jones. No smoking or oral intake of any material during this time; if vomiting occurs, start over with the 15 minute observation period. 2. Assure that power switch is ON and then press the START TEST button. 3. Enter the test record card. 4. Enter subject and officer information. 5. When display reads PLEASE BLOW, insert mouthpiece and take the subject's breath sample. 6. When test record is printed remove test record and attach printout to this report."

The officer never attached a breath test ticket to his report. The certification section provided that: "AS SET FORTH IN THE RULES PROMULGATED BY THE DEPARTMENT OF HEALTH RELATED TO THE DETERMINATION OF BLOOD ALCOHOL BY BREATH ANALYSIS, I CERTIFY BY COMPLETING THE BELOW THAT: 1. There was no deviation from the procedure approved by the department. 2. To the best of my knowledge the instrument was functioning properly. 3. I am authorized to operate the instrument. 4. No radio transmission occurred inside the room where and when this test was being conducted."

Mr. Ward argued, and the trial court found, that because the officer completed the checklist and certification section, indicating that a test had been given, there was a conflict in the records as to whether or not Reece refused the breath test. The trial court ruled in Reece’s favor and Director appealed. The Eastern District Court of Appeals affirmed the trial court, noting that "this case demonstrates the difficulties that can arise when the case is submitted on the records and the evidence conflicts. Caution should be exercised when a suspension case is submitted on the records alone ... submission of a case on the records alone may pose some risks--including the inability to explain discrepancies or to rehabilitate witnesses."

Richardson v. Dir. of Revenue, 165 S.W.3d 236 (Mo. App. S.D. 2005). The facts in this case were very similar to the facts in Reece. This time, the Southern District Court of Appeals affirmed the trial court’s decision setting aside the revocation of Richardson’s driving privileges for allegedly refusing a breath test based upon the contradictory nature of the arrest report.

Russell v. Dir. of Revenue, 83 S.W.3d 72 (Mo. App. W.D. 2002). Here, Russell had an old BAC conviction on his driving record. More than 10 years after his conviction, Russell was again arrested and charged with driving while intoxicated. Mr. Ward requested a hearing for Mr. Russell, and the hearing officer determined that there wasn’t probable cause to arrest Russell on the new charge and removed the administrative suspension from his drivers license. Russell then filed a petition for expungement. Under the expungement statute, Russell is entitled to an expungement so long as he can prove that he hadn’t received any alcohol related suspensions, revocations or convictions within ten years prior to the filing of the petition for expungement. The DWI charge had not gone to trial at the time of filing. The Western District Court of Appeals determined that the trial court erred when it denied Russell’s petition for expungement, as the driver had not been convicted of any alcohol-related driving offense prior to applying for expungement.

Stolle v. Director of Revenue, 179 S.W.3d 470 (Mo. App. E.D. 2005) Here, the officer arrived at the scene of a one vehicle accident. She encountered an unoccupied vehicle parked on the street with heavy front end damage. The officer checked the registration, determined who owned the vehicle, and proceeded to that address. The officer arrived at the driver's home over a half hour later. The officer testified that she smelled alcohol when speaking with the driver, but she did not know when the driver had consumed the alcoholic beverages. The officer administered the horizontal gaze nystagmus test, but the officer admitted that she failed to administer the test properly. The officer did not administer any other field sobriety tests. She conceded that a properly trained, prudent police officer would not have relied on an improperly administered field sobriety test as probable cause for arrest. The court noted that while the officer did not need to observe the driver actually driving to establish probable cause, there had to be circumstantial evidence which rose to the level of probable cause to believe the driver was driving while intoxicated in order to arrest her. The court decided that there was insufficient circumstantial evidence. The mere fact that a person has consumed alcoholic beverages at some undetermined point in time cannot give rise to probable cause that the person is intoxicated. The decision of the trial court setting aside Stolle’s suspension was affirmed.

Special Honors and Recognition

In July of 2006, Carl Ward was presented with the prestigious “Robert Duncan Award of Appellate Excellence” by the Missouri Association of Criminal Defense Lawyers. In the Spring of 2007, he was elected to serve as a member of the Board of Directors of the same organization. Recently, he was selected by Thompson -West Publishing Company to co-author with Missouri attorney, Jeffrey Eastman, a book entitled: “ Missouri Driver’s License and DWI Defense.” This book will serve as the “Bible” of DWI / DUI defense for attorneys in the State of Missouri. It is expected to be printed in the Spring/Summer of 2008. Only the most knowledgeable lawyers in the field are selected to author publications for Thompson-West. Carl and Jeff will join other notable Thompson -West Publishing Company authors on the subject of DWI / DUI (drunk driving) defense, including: William Head, Georgia; Steve Oberman, Tennessee; Lawrence E. Taylor, California; and Edward Fiandach , New York.

Disclaimer

• “The choice of a lawyer is an important decision and should not be based solely on advertisements.” Rule 4-7.2
• “Neither the Supreme Court of Missouri nor The Missouri Bar reviews or approves certifying organizations or speciality designations.” Rule 4-7.4
• “Past results afford no guarantee of future results. Every case must be judged on its own merits.” Rule 4-7.1