Justia Missouri Supreme Court Opinion Summaries

Presley Karlin, a 17-year-old, was injured at Urban Air Springfield, a trampoline and adventure park, due to allegedly inadequate protective cushions. After turning 18, Karlin sued Urban Air for negligence. Urban Air responded by filing a motion to compel arbitration based on an arbitration agreement signed by Karlin’s mother on his behalf. Karlin argued that his mother lacked the authority to sign the agreement and that the agreement only applied to claims arising on the day it was signed, not to his injury four months later.The Circuit Court of Greene County overruled Urban Air’s motion to compel arbitration. Urban Air appealed, limiting its arguments to the arbitration agreement signed by Karlin’s mother. The court reviewed the case de novo, focusing on whether the arbitration agreement contained a delegation clause that required threshold issues of arbitrability to be decided by an arbitrator.The Supreme Court of Missouri found that the arbitration agreement did contain a delegation clause, which required any disputes about the scope, arbitrability, or validity of the agreement to be settled by arbitration. Since Karlin did not specifically challenge the delegation clause itself, the court held that the clause was valid and enforceable. Consequently, Karlin’s claims regarding the validity and scope of the arbitration agreement must be presented to the arbitrator.The Supreme Court of Missouri vacated the circuit court’s order and remanded the case with instructions to sustain Urban Air’s motion to compel arbitration. View "Karlin vs. UATP Springfield, LLC" on Justia Law

In 2019, fourth-grader D.J. was attending KIPP Victory Academy, which had contracted with First Student, Inc. to transport students. On October 23, 2019, substitute bus driver Tomika Richardson dropped D.J. off at the wrong corner of an intersection. The next day, Richardson again dropped D.J. off at the same incorrect location. As D.J. crossed the street, a vehicle maneuvered around the bus and struck him, causing injuries. The hit-and-run driver was never identified. D.J., through his mother, sued First Student and Richardson, alleging negligence.The case went to trial in the Circuit Court of St. Louis. The jury found in favor of Richardson on one count but ruled in favor of D.J. on another count, awarding $1.3 million in damages. The circuit court overruled First Student's motions for judgment notwithstanding the verdict (JNOV) and a new trial, leading to First Student's appeal.The Supreme Court of Missouri reviewed the case. The court held that the criminal act of the hit-and-run driver was an intervening and superseding cause, breaking the causal chain and relieving First Student of liability. The court determined that D.J. failed to prove that First Student's actions were the proximate cause of his injuries. Consequently, the Supreme Court of Missouri vacated the circuit court's judgment and remanded the case with instructions to enter judgment in favor of First Student. View "D.J. v. First Student, Inc." on Justia Law

F.S. was found guilty by a jury of statutory sodomy of an 11-year-old victim and sentenced to five years in prison. After completing her sentence and parole, she was subjected to lifetime electronic monitoring by the Missouri Department of Corrections under section 217.735. This monitoring involves wearing an ankle bracelet that tracks her location via GPS. F.S. challenged the constitutionality of this lifetime monitoring requirement, arguing it violated her Fourth Amendment rights.The Circuit Court of Cole County upheld the constitutionality of section 217.735. During the bench trial, the court received stipulated facts, exhibits, and testimony from experts. The court found that GPS monitoring can deter recidivism among sex offenders by enforcing exclusion zones and increasing the certainty of legal repercussions. The court also noted that F.S. had not reoffended since completing parole but found that sex offenders with child victims tend to reoffend over a longer period. The court concluded that the GPS monitoring was a reasonable search under the Fourth Amendment, given F.S.'s diminished expectation of privacy as a convicted sex offender and the state's legitimate interest in protecting potential victims.The Supreme Court of Missouri reviewed the case de novo and affirmed the circuit court's judgment. The court held that F.S. failed to present particularized evidence showing that section 217.735 was unconstitutionally applied to her circumstances. The court emphasized that F.S.'s status as a female offender and her lack of reoffending did not suffice to demonstrate that the statute was unreasonable as applied to her. The court concluded that the statute did not clearly contravene any specific constitutional provision and upheld the lifetime monitoring requirement. View "F.S. v. Missouri Department of Corrections, Division of Probation and Parole" on Justia Law

Great Plains Trucking Inc. and Lennis H. Beck (defendants) appealed a circuit court judgment in favor of Carrie S. Schultz and Robert C. Schultz, Sr. (plaintiffs), surviving parents of Robert C. Schultz, Jr., in a wrongful death action. Beck, a truck driver for Great Plains, collided with the plaintiffs' vehicle, resulting in the death of their son. The collision occurred in Wentzville, Missouri, under dark and rainy conditions. The plaintiffs' vehicle had fishtailed and was struck by another vehicle before Beck's truck collided with it.The Circuit Court of St. Charles County held a jury trial, which resulted in a verdict awarding the plaintiffs $10,000,000 in compensatory damages, $10,000,000 in aggravating circumstances damages against Great Plains, and $25,000 in aggravating circumstances damages against Beck. The circuit court entered judgment in accordance with the jury's verdicts and awarded post-judgment interest. The defendants filed a post-trial motion for a new trial or judgment notwithstanding the verdict, which the circuit court overruled. The defendants then appealed.The Supreme Court of Missouri reviewed the case and affirmed the circuit court's judgment. The court found that the defendants did not preserve their claims of error for appellate review or that their preserved claims failed on the merits. Specifically, the court held that the defendants failed to preserve the issue of excluding expert testimony regarding the mother's impairment by THC because they did not object at trial. Additionally, the court found that the defendants did not preserve their objection to the participation of separate counsel for the plaintiffs throughout the trial.The court also held that there was substantial evidence to support the jury's finding that Beck failed to keep a careful lookout and that the jury's award of aggravating circumstances damages against both Beck and Great Plains was supported by sufficient evidence. The court concluded that Beck's multiple violations of the Missouri CDL manual and Great Plains' acceptance of Beck's conduct demonstrated complete indifference or conscious disregard for the safety of others. View "Schultz vs. Great Plains Trucking, Inc." on Justia Law

A nurse at a Missouri Department of Mental Health facility assaulted Vernell Beach, a non-verbal, developmentally disabled patient. The nurse was charged with second-degree assault and armed criminal action. Beach's legal guardian sued the nurse, who did not respond to the lawsuit, resulting in a default judgment. The nurse later pleaded guilty to third-degree assault, and the attorney general withdrew from representing her. A second default judgment awarded Beach $8 million plus interest. When the state refused to pay from the State Legal Expense Fund, Beach sought a writ of mandamus in the Cole County circuit court.The Cole County circuit court granted a permanent writ of mandamus directing the state to release the funds to satisfy the judgment. However, the court did so without first issuing a preliminary order in mandamus, which is required to initiate responsive pleadings and allow the state to contest the facts and raise defenses.The Supreme Court of Missouri reviewed the case and found that the circuit court's failure to issue a preliminary order in mandamus materially affected the merits of the action. The preliminary order is essential for initiating responsive pleadings and ensuring a fair process. Consequently, the Supreme Court of Missouri vacated the circuit court's judgment and remanded the case for further proceedings consistent with its opinion. View "Beach v. Zellers" on Justia Law

Jeromy McCrackin filed a wrongful death action against Tynan Mullen for the death of McCrackin’s son, who was shot and killed outside a pool hall in 2019. Safeco Insurance Company of America had issued a homeowners insurance policy to Mullen’s grandmother, with whom Mullen allegedly lived at the time. Mullen was indicted for first-degree murder and armed criminal action but pleaded guilty to first-degree involuntary manslaughter and armed criminal action. McCrackin offered to settle the wrongful death claim against Mullen in exchange for Safeco’s agreement to pay the total liability coverage limits, which Safeco declined, stating the policy excluded coverage for intentional acts.The Circuit Court of Jackson County overruled Safeco’s motion to intervene in the wrongful death action for the purpose of seeking a stay until a separate federal declaratory judgment action could be resolved. Safeco had filed the federal action to determine whether it had a duty to defend or indemnify Mullen. The circuit court held a bench trial in the wrongful death action, overruled Safeco’s motion to intervene, and entered a judgment against Mullen, awarding McCrackin $16.5 million in damages.The Supreme Court of Missouri reviewed the case and held that Safeco had a right to intervene in the wrongful death action pursuant to Rule 52.12(a)(2) for the limited purpose of seeking a stay. The court found that Safeco had an interest in the wrongful death action and that the disposition of the action could impair or impede its ability to protect that interest. The court vacated the circuit court’s judgment and remanded the case for further proceedings consistent with its opinion. The court did not direct how the circuit court should rule on the motion to stay, leaving that decision to the lower court. View "McCrackin vs. Mullen" on Justia Law

Joe David Hudson was injured while working for Joplin Regional Stockyards, Inc. (JRS) in 2002. In 2005, Hudson, JRS, and JRS' insurer, Star Insurance Company, entered into a settlement agreement where Hudson received an $80,000 lump sum. The settlement left future medical expenses for Hudson's left ankle open. In 2011, Hudson had a below-the-knee amputation, which Star refused to cover. Hudson filed the settlement in circuit court in 2013, and the court rendered judgment in accordance with the settlement. Hudson later filed an equitable garnishment action, leading Star to pay $92,000 for his medical bills. In 2015, Star agreed to reimburse Hudson up to $610,311.75 for future medical expenses. In 2016, Hudson and JRS entered into a subordination agreement, acknowledging all payments due under the judgment had been received.In 2022, Hudson filed a motion to revive the judgment, which JRS opposed, arguing the judgment had been satisfied and the Division of Workers' Compensation had not determined the future medical care provision. JRS also filed a motion for relief from the judgment, claiming it was void due to lack of due process. The Circuit Court of Jasper County sustained Hudson's motion to revive the judgment and overruled JRS' motion for relief.The Supreme Court of Missouri reviewed the case and determined that JRS had standing to appeal. The court found that the circuit court erred in reviving the judgment because JRS had satisfied the judgment by paying the $80,000 lump sum. The court reversed the circuit court's order sustaining Hudson's motion to revive the judgment and overruled Hudson's motion to revive the judgment. Hudson's motion for damages for a frivolous appeal was also overruled. View "Hudson v. Joplin Regional Stockyards, Inc." on Justia Law

A tract of land was platted into a subdivision for single-family residential use, with restrictions recorded by the original owner. A subsequent purchaser, Ananda LLC, acquired the subdivision and attempted to develop it contrary to the restrictions. When these plans failed, Ananda transferred some lots to Nithyananda Dhyanapeetam of St. Louis and the remaining lots to Fogarty Farms LLC, which also received an assignment of developer rights. The case centers on whether developer rights were transferred and if the subdivision's restrictions were abandoned.The Circuit Court of Jefferson County found that developer rights were transferred from the original owner to Ananda and then to Fogarty Farms. The court held that the restrictions were not abandoned and that the property owners association created under the restrictions was valid. The court also invalidated a transfer of common ground and awarded attorney fees to the property owners association.The Supreme Court of Missouri reviewed the case and affirmed the circuit court's judgment. The court held that the totality of circumstances demonstrated the intent to transfer developer rights from Essex to Ananda and then to Fogarty Farms. The court also found that the restrictions were not abandoned, as there were no widespread violations indicating an intent to abandon the plan. The court upheld the circuit court's decision that the lake lot remained common ground, as removing it would be unjust given Nithyananda's reliance on its status. Finally, the court affirmed the award of attorney fees to the property owners association, finding no abuse of discretion in the amount awarded. View "Millstone Property Owners Association vs. Dhyanapeetam" on Justia Law

Yolanda Bell obtained an automobile insurance policy from Shelter General Insurance Company. In February 2018, her vehicle was damaged, and Shelter determined it was a total loss, paying her $11,787 after deductions. Bell filed a class action suit in February 2022, alleging that Shelter breached its contractual duties by not including taxes and fees required to acquire a replacement vehicle in its payment. Bell argued that the policy did not require her to replace the vehicle before being reimbursed for these costs.The Circuit Court of Jackson County dismissed Bell's petition without prejudice, agreeing with Shelter's argument that the policy only covered taxes and fees if they were actually incurred by purchasing a replacement vehicle. Bell appealed the decision, standing on her original petition rather than amending it.The Supreme Court of Missouri reviewed the case de novo. The court found that Bell's petition adequately pleaded a breach of contract claim by alleging the existence of the insurance policy, her performance under the policy, Shelter's failure to pay the required taxes and fees, and the resulting damages. The court emphasized that the interpretation of the policy's terms was a matter for summary judgment or trial, not for a motion to dismiss. Consequently, the Supreme Court of Missouri reversed the circuit court's judgment and remanded the case for further proceedings. View "Bell vs. Shelter General Insurance Company" on Justia Law

In the early morning, a police officer stopped Chad Thomas for driving with a broken headlight. During the stop, Thomas exhibited unusual behavior, such as rolling down the rear window instead of the front, being unable to find his driver’s license, and acting nervously. The officer conducted a pat-down search, during which Thomas mentioned he might have a "sharp," a term the officer associated with drug use. Thomas's behavior, including blocking the officer's view and lying about having his license, led the officer to call for a canine unit, which eventually alerted to the presence of drugs.The Circuit Court of Saline County overruled Thomas's motion to suppress the evidence found during the search, concluding that the officer had reasonable suspicion to extend the stop based on Thomas's behavior. The court found that the extension of the stop was justified by Thomas's actions and the need to verify his identity and the outstanding warrant. The court admitted the evidence, and the jury found Thomas guilty of possession of a controlled substance and unlawful possession of drug paraphernalia. Thomas was sentenced to 10 years in prison.The Supreme Court of Missouri reviewed the case and affirmed the circuit court’s judgment. The court held that the officer had reasonable suspicion to extend the traffic stop based on the totality of Thomas's behavior, which included nervousness, evasive actions, and inconsistent statements. The court found that the detention and subsequent search were lawful under the Fourth Amendment, as the officer's actions were justified by reasonable suspicion of criminal activity. View "State vs. Thomas" on Justia Law