Justia Missouri Supreme Court Opinion Summaries

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Shelter Mutual Insurance Company issued the Swadley family a policy with underinsured motorist (UIM) coverage. The policy’s declarations page listed “100,000 Per Person” as the UIM limit. After Angela Swadley was killed in a collision, the Swadleys made a claim to Shelter pursuant to their policy’s UIM coverage. When Shelter denied the claim, the Swadleys filed a petition against Shelter. The circuit court ruled that the policy was ambiguous, entered partial summary judgment in favor of the Swadleys and awarded the Swadleys $100,000. The Supreme Court reversed, holding that the policy unambiguously precluded UIM coverage from applying to the Swadleys’ claim. View "Swadley v. Shelter Mutual Insurance Co." on Justia Law

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After a jury trial, Defendant was convicted of first-degree burglary, misdemeanor stealing, and driving while revoked. Defendant appealed, arguing that there was insufficient evidence to support his conviction for first-degree burglary and that the circuit court abused its discretion by admitting testimony that demonstrated Defendant’s propensity to engage in criminal activity. The Supreme Court affirmed, holding (1) there was sufficient evidence to convict Defendant of first-degree burglary; and (2) the circuit court did not abuse its discretion in admitting the evidence of uncharged misconduct on the basis that it had a “legitimate tendency to directly establish the defendant’s guilty of the charge for which he [was] on trial.” View "State v. Naylor" on Justia Law
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When Child was not yet one year old, Grandfather filed a petition to establish a guardianship and conservatorship jointly in two cousins, alleging that Mother was unable or unfit to assume the duties of guardianship. After a hearing, the trial court found Mother unable and unfit to properly care for Child and ordered the issuance of letters of guardianship and conservatorship to the two cousins as co-guardians. Mother appealed, arguing that the trial court had utilized the wrong burden of proof and that due process requires proof of unfitness by clear and convincing evidence. The Supreme Court affirmed, holding (1) Mo. Rev. Stat. 475.030.4 requires proof of inability or unfitness by a preponderance of the evidence, and Mother failed to preserve her argument that the statute is unconstitutional; (2) the trial court’s judgment ordering the issuance of letters of guardianship and conservatorship was supported by substantial evidence and was not against the weight of the evidence; and (3) the trial court did not abuse its discretion in overruling Mother’s motion for a continuance. View "In re A.L.R." on Justia Law
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Missouri American Water Company (MAWC) filed a petition to charge an infrastructure system replacement surcharge to its St. Louis County customers. The Public Service Commission (PSC) approved the petition. The Office of the Public Counsel appealed, arguing that the PSC lacked the authority to grant the petition because St. Louis County did not meet Mo. Rev. Stat. 393.1000-393.1006’s threshold population requirement at the time PSC approved the surcharge. The Office of the Public Counsel appealed. While the appeal was pending, MAWC and PSC reached an agreement establishing a new rate base that incorporated the costs of the MAWC projects for all then-existing surcharges. The Supreme Court dismissed this case as moot, holding (1) because the surcharge is no longer in effect and no effective relief may be granted, the issue as to whether MAWC can utilize the surcharge provisions of section 393.1003 is moot; and (2) the issues presented on appeal did not meet the requirements for an exception to the mootness doctrine. View "In re Petition of Missouri-American Water Company for Approval to Change its Infrastructure System Replacement Surcharge" on Justia Law

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After a jury trial, Appellant was found guilty of second-degree statutory rape and the class D felony of incest. Appellant’s convictions and sentences were affirmed. Appellant later filed a pro se motion for postconviction DNA testing pursuant to Mo. Rev. Stat. 547.035. The circuit court overruled and denied Appellant’s motion. Appellant was not notified of any proceedings in his case and requested additional information. The circuit court failed to provide the requested information. On appeal, the court of appeals, sua sponte, determined that it did not have jurisdiction to consider the appeal because the circuit court’s docket entry was not denominated a judgment. The Supreme Court granted transfer and reversed and remanded, holding that there could be no meaningful appellate review due to the circuit court’s failure to issue findings of fact and conclusions of law as required by Mo. Rev. Stat. 547.035.8. View "Mercer v. State" on Justia Law
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St. Louis City’s Ordinance 70078 establishes a citywide local minimum wage. The trial court invalidated the Ordinance because it requires a higher minimum wage than the state requires in Mo. Rev. Stat. 290.502. In so ruling, the trial court concluded that Mo. Rev. Stat. 71.010, which includes a general prohibition on local laws that conflict with state laws, would bar such supplemental local minimum wage ordinances. The Supreme Court reversed the portion of the judgment invalidating Ordinance 70078, holding (1) the trial court correctly found that Mo. Rev. Stat. 67.1571 does not preempt Ordinance 70078 because section 67.1571 was enacted in a manner that violates Mo. Const. art. III, 23; (2) Missouri’s minimum wage law does not occupy the field of minimum wage laws, nor does it prohibit the adoption of local minimum wage ordinances such as Ordinance 70078; and (3) Ordinance 70078 is within the municipality’s police powers, and the City did not exceed its authority in enacting the minimum wage ordinance. View "Cooperative Home Care, Inc. v. City of St. Louis" on Justia Law
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David DePriest and Natalie DePriest, brother and sister, were charged separately with offenses arising from their cultivation of marijuana plants. The DePriests were represented by the same counsel throughout their separate criminal proceedings. The DePriests jointly pleaded guilty pursuant to a plea deal on counsel’s recommendation. The trial court accepted both DePriests’ pleas. Thereafter, the DePriests filed separate motions for postconviction relief pursuant to Mo. R. Crim. P. 24.035, alleging ineffective assistance of counsel because defense counsel continued to represent both of them long after it became clear during the plea negotiations that there was an actual conflict of interest between them. The motion court denied both motions without an evidentiary hearing. The Supreme Court vacated the motion court’s judgments and remanded the cases for further proceedings, holding that both David and Natalie alleged sufficient facts to state a claim of ineffective assistance of counsel under Rule 24.035, and therefore, the motion court erred in denying the DePriests an evidentiary hearing. Remanded. View "DePriest v. State" on Justia Law

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Russel Parker, an Indiana resident, brought a personal injury action against Norfolk Southern Railway Company, a Virginia corporation, under the Federal Employer’s Liability Act, alleging cumulative trauma sustained during his years of employment with Norfolk in Indiana. Norfolk moved to dismiss for lack of personal jurisdiction alleging that Missouri had no personal jurisdiction. The trial court overruled the motion without stating the grounds for its ruling. Norfolk sought a writ of prohibition directing the trial court to dismiss the suit. The Supreme Court issued a preliminary writ of prohibition, which it subsequently made permanent, holding that Missouri did not have specific or general personal jurisdiction over Norfolk in the underlying personal injury action. View "State ex rel. Norfolk Southern Railway Co. v. Hon. Colleen Dolan" on Justia Law

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David and Crystal Holm filed a wrongful foreclosure action against Wells Fargo Home Mortgage, Inc. for allegedly foreclosing on their home without right. The Holms also filed a quiet title action against Freddie Mac, which took title to the property after the foreclosure sale. After a jury-waived trial, the trial court entered judgment in favor of the Holms on their wrongful foreclosure claim, awarded them actual and punitive damages, and quieted title to the house in the Holms. The mortgage companies appealed. The Supreme Court affirmed in part and reversed in part, holding (1) the trial court did not abuse its discretion in sanctioning the mortgage companies for their discovery violations; (2) substantial evidence supported the trial court’s conclusion that Wells Fargo wrongfully foreclosed on the Holms’ house; but (3) the trial court erred in awarding damages and quieting title to the house in the Holms because the mortgage companies had a constitutional right to have a jury determine the extent of the Holms’ actual and punitive damages on the wrongful foreclosure claim. Remanded for a new trial before a jury on the Holms’ damages for wrongful foreclosure. View "Holm v. Wells Fargo Home Mortgage, Inc." on Justia Law

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In 1998, 52 U.S. states and territories entered into the Master Settlement Agreement (MSA) with tobacco manufacturers (PMs), which released the PMs from tobacco-related consumer protection and product liability lawsuits in return for the PMs’ agreement to make annual payments to the states in perpetuity. This dispute concerned the application of the Non-Participating Manufacturer Adjustment (NPM Adjustment), a provision in the MSA that reduces the amount the PMs must pay to states that failed diligently to enforce certain legislation during a relevant year. PMs, Missouri, and other states arbitrated the dispute. More than twenty states and the PMs entered into a partial settlement agreement, but Missouri and other states did not join the settlement. The arbitration panel found that Missouri was not diligent in enforcing its legislative enactment and that the NPM Adjustment applied. Missouri sought relief. The trial court overruled Missouri’s motion to compel the PMS to engage in a single-state arbitration with Missouri over another dispute regarding application of the NPM Adjustment in a subsequent year but modified the award as requested by Missouri. The Supreme Court affirmed, holding (1) the trial court correctly refused to compel single-state arbitration; and (2) the trial court did not err in modifying the panel’s award. View "State ex rel. Greitens v. American Tobacco Co." on Justia Law