
Quoting
In re Dyer, 163 S.W.3d 915 (Mo. S.Ct. 2005)
To establish that the arrest was based on "false information" the petitioner in most cases must prove that the alleged victim - who knew the petitioner and on whose accusation his arrest was based - had falsely accused the petitioner. Martinez v. State, 24 S.W.3d 10, 20 (Mo. App. 2000). In all cases, the petitioner must prove that some or all of the information upon which the police relied to arrest the petitioner is simply a lie.
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The false information requirement and the probable cause requirement, when combined, "necessarily imply and mean that a petitioner . . . has the burden to affirmatively demonstrate at a hearing, by a preponderance of the evidence . . . his actual innocence of the offense for which he was arrested." Martinez, 24 S.W.3d at 20. The fact that Dyer pled guilty and received a probation sentence seems to indicate that he was not actually innocent of the stealing and forgery, unless the court is willing to believe that Dyer falsely or mistakenly pleaded guilty in 1991.