Justia Missouri Supreme Court Opinion Summaries

In 2015, the Missouri General Assembly enacted sections 67.287 and 479.359.2, which imposed certain standards and revenue caps on municipalities, specifically targeting St. Louis County. The City of Normandy and other municipalities challenged these statutes, claiming they violated the Missouri Constitution's prohibition against local or special laws. In 2016, the Circuit Court of Cole County declared these sections unconstitutional and issued a permanent injunction against their enforcement. The Missouri Supreme Court affirmed this decision in City of Normandy v. Greitens.Following a shift in legal analysis in City of Aurora v. Spectra Communications Group, LLC, the state sought relief from the 2016 injunction, arguing that the statutes would have survived under the new rational basis review. The circuit court initially granted this relief, but the Missouri Supreme Court vacated that judgment in City of Normandy v. Parson, remanding the case for further proceedings. On remand, the circuit court overruled the state's motion for partial relief from the judgment.The Missouri Supreme Court reviewed the case and affirmed the circuit court's decision. The court held that the change in legal analysis from City of Aurora did not automatically warrant relief from the permanent injunction under Rule 74.06(b)(5). The court emphasized the importance of finality in judgments and found that the state did not demonstrate sufficient inequity to justify lifting the injunction. The court also noted that the state had not sought relief from the declaratory judgment that the statutes were unconstitutional, which remained in effect. Therefore, the circuit court did not abuse its discretion in denying the state's motion for relief. View "City of Normandy v. Kehoe" on Justia Law

David Thompson was convicted of fourth-degree domestic assault and violating an order of protection. He appealed, arguing that the circuit court made three errors: (1) denying his motion to dismiss due to lack of counsel at his preliminary hearing, (2) rejecting his proposed lesser-included offense instruction for fourth-degree domestic assault, and (3) submitting a corrective instruction after the jury announced its verdicts.Thompson was charged with felony domestic assault for hitting his ex-boyfriend with a vehicle, violating a protective order. At his preliminary hearing, Thompson was unrepresented, and the associate circuit division found probable cause to proceed to trial. Thompson later moved to dismiss, claiming his right to counsel was violated, but the circuit court denied the motion. At trial, the jury was instructed on third-degree domestic assault and a lesser-included offense of fourth-degree domestic assault. The jury found Thompson not guilty of third-degree domestic assault but guilty of the lesser charge and violating the protective order. After the verdicts, the court discovered inconsistent verdicts for Count I and issued a corrective instruction, leading the jury to clarify its guilty verdict for fourth-degree domestic assault.The Supreme Court of Missouri reviewed the case. It held that Thompson's right to counsel was not violated because he had ample opportunity to retain counsel but failed to do so. The court also found no error in the circuit court's rejection of Thompson's proposed instruction, as the given instruction was appropriate and there was no rational basis for the jury to acquit him of the charged offense while convicting him of the lesser-included offense. Lastly, the court ruled that the corrective instruction was proper and did not prejudice Thompson, as the jury had not been discharged and the court acted within its authority to resolve the inconsistency.The Supreme Court of Missouri affirmed the circuit court's judgment. View "State v. Thompson" on Justia Law

In July 1991, Christopher Dunn was convicted of first-degree murder, two counts of first-degree assault, and three counts of armed criminal action. He was sentenced to life in prison without parole for the murder, 30 years for each assault, and 10 years for each armed criminal action, all to be served consecutively. In February 2024, the St. Louis circuit attorney filed a motion to vacate Dunn’s convictions, citing new evidence of actual innocence. The circuit court held an evidentiary hearing and found clear and convincing evidence of Dunn’s innocence, vacating his convictions and ordering his release. The attorney general opposed this and filed a notice of appeal.The circuit court ordered Dunn’s release, but the attorney general sought a writ of prohibition or mandamus from the Supreme Court of Missouri to prevent the release. The Supreme Court issued a temporary stay and later a permanent writ prohibiting Dunn’s release without the state’s intent to retry him. The circuit court amended its judgment, and Dunn was released after the circuit attorney filed a memorandum of nolle prosequi. The attorney general appealed, but the circuit attorney moved to dismiss, arguing the state had no right to appeal under section 547.031.The Supreme Court of Missouri reviewed whether the state could appeal the judgment vacating Dunn’s convictions. The court held that the state is an aggrieved party with a statutory right to appeal under section 512.020(5). The court found that section 547.031 did not limit the state’s right to appeal and that the state’s interest in the finality of its convictions made it an aggrieved party. The court retransferred the case to the court of appeals to overrule the circuit attorney’s motion to dismiss and proceed with the state’s appeal on the merits. View "In re: Circuit Attorney, 22nd Judicial Circuit ex rel. Dunn" on Justia Law

Anthony Tate was convicted of first-degree murder, two counts of first-degree assault, unlawful use of a weapon, unlawful possession of a weapon, and four counts of armed criminal action. The charges stemmed from an incident where Tate fired 15 shots into a vehicle, killing one passenger and injuring two others. The injured passengers, A.H. and M.E., sustained gunshot wounds that required medical treatment and resulted in protracted impairment. Tate was identified through video surveillance and social media posts, and the gun used in the shooting was found in his possession.The Circuit Court of St. Louis County found Tate guilty on all counts. Tate appealed, challenging the sufficiency of the evidence for the first-degree assault convictions, the failure of the circuit court to issue a corrective instruction regarding the State’s closing argument, and the admission of hearsay testimony from a detective. The Missouri Court of Appeals reviewed the case and upheld the circuit court’s judgment.The Supreme Court of Missouri affirmed the lower court’s decision. The court held that there was sufficient evidence to support the first-degree assault convictions, as the injuries sustained by A.H. and M.E. constituted serious physical injury with protracted impairment. The court also found no plain error in the circuit court’s failure to issue a corrective instruction regarding the State’s closing argument or in admitting the detective’s testimony. The court concluded that the evidence presented at trial was sufficient for a reasonable juror to find Tate guilty beyond a reasonable doubt. View "State v. Tate" on Justia Law

Ethel Barry Masters filed a petition against Jacob Dawson in 2019, alleging replevin, conversion, and unjust enrichment after Dawson refused to surrender possession of four vehicles that belonged to Masters' deceased long-term companion. Dawson disputed ownership and obstructed the legal process, including failing to respond to requests for admissions and barricading the vehicles to prevent towing. The circuit court granted partial summary judgment in favor of Masters, ordering Dawson to surrender the vehicles, which he did not comply with. Dawson's attorney withdrew due to ethical concerns, and subsequent attorneys also withdrew due to Dawson's failure to pay legal fees.The Circuit Court of St. Louis County scheduled multiple trial dates, which were postponed due to Dawson's actions, including retaining new attorneys and filing motions for continuance. Dawson failed to appear for a pretrial conference, leading the circuit court to cancel the jury trial and enter a default judgment in favor of Masters, awarding her $83,035.41 in actual damages and an equal amount in punitive damages. Dawson's conduct was deemed contemptuous, justifying punitive damages to deter similar behavior.The Supreme Court of Missouri reviewed the case and found that Dawson's constitutional claims regarding the right to a jury trial were unpreserved because he did not adequately raise them in his motion for a new trial. The court held that the circuit court did not abuse its discretion by sanctioning Dawson due to his pattern of obstructive behavior. The Supreme Court of Missouri affirmed the circuit court's judgment, upholding the damages awarded to Masters. View "Masters v. Dawson" on Justia Law

Connie Lange purchased a fifth-wheel camping trailer from GMT Auto Sales in August 2020, which included a $199 administrative fee. Lange later filed a class action petition alleging that GMT violated the Missouri Merchandising Practices Act by charging this fee, arguing that fifth-wheel camping trailers do not qualify as "motor vehicles," "vessels," or "vessel trailers" under the relevant statute. GMT initially moved to dismiss the case but later moved to compel arbitration based on an arbitration clause in the retail installment contract.The Circuit Court of St. Louis County overruled GMT's motion to dismiss and later granted GMT's motion to compel arbitration. The arbitrator awarded Lange $199 and $5,000 in attorney fees. Lange then filed a motion to vacate the arbitration award and reconsider the order compelling arbitration, which the circuit court denied. Lange appealed, arguing that GMT waived its right to arbitration by filing the motion to dismiss and that the arbitration provision was unenforceable.The Missouri Court of Appeals reversed the circuit court's judgment, agreeing with Lange that GMT waived its right to arbitration. The Supreme Court of Missouri granted transfer and reviewed the case de novo. The court found that GMT did not waive its right to arbitration by filing the motion to dismiss, as it timely moved to compel arbitration and raised it as an affirmative defense in its responsive pleading. The court also found that the arbitration provision remained enforceable despite the assignment of the retail installment contract to a bank. Lange's argument regarding the unconscionability of the arbitration provision was deemed unpreserved for review.The Supreme Court of Missouri affirmed the circuit court's judgment confirming the arbitration award. View "Lange v. GMT Auto Sales, Inc." on Justia Law

Scott Frey was injured while riding his bike on the Katy Trail in March 2020. He alleged that his injury occurred when his bike tire became lodged between wooden motor-vehicle reinforcements on a bridge managed by the Department of Natural Resources. Frey had not paid any fee to enter the trail and was using it for recreational purposes. The department had installed the reinforcements shortly before the accident and had posted warning signs about the rough surface.Frey filed a personal injury lawsuit against the department, claiming the bridge's condition was dangerous due to the department's negligence. The department sought summary judgment, arguing it was protected from liability under the Recreational Use Act and the doctrine of sovereign immunity. The circuit court denied the department's motion, and the department's request for a writ of prohibition was also denied by the court of appeals.The Supreme Court of Missouri reviewed the case and determined that the Recreational Use Act provided the department with immunity from liability. The court found that the department met all the criteria for immunity under the Act: it owned the land, Frey entered without charge, and his entry was for recreational purposes. The court also concluded that the exceptions to the Act's protections did not apply, as there was no evidence of malicious or gross negligence by the department, nor was the condition of the bridge considered ultrahazardous. Consequently, the court made the preliminary writ of prohibition permanent, effectively barring Frey's claims against the department. View "State ex rel. Department of Natural Resources v. Crane" on Justia Law

In March 2022, Brian Milazzo was stopped at a driver’s license checkpoint in Randolph County, Missouri. Milazzo, who was driving a pickup truck with a passenger, did not have his driver’s license but had proof of insurance on his phone. After being asked to pull over, the officers noticed the passenger was not wearing a seatbelt and refused to identify himself. The officers decided to arrest the passenger for failing to wear a seatbelt. When the passenger refused to exit the vehicle, the officers instructed Milazzo to unlock the passenger-side door multiple times. Milazzo did not comply, leading the officers to break the window to arrest the passenger. Milazzo was subsequently arrested and charged with interfering with an arrest.The Circuit Court of Randolph County overruled Milazzo’s motions for judgment of acquittal, and the jury found him guilty of interfering with an arrest. Milazzo was sentenced to 21 days in jail. He appealed the conviction, arguing insufficient evidence to support the charge, specifically that failing to unlock the door did not constitute physical interference.The Supreme Court of Missouri reviewed the case. The court held that the evidence was sufficient to support the conviction. The court interpreted the statute on interfering with an arrest to include not only affirmative acts but also omissions that hamper law enforcement. The court found that Milazzo’s refusal to unlock the door constituted physical interference as it created a material barrier to the officers’ ability to arrest the passenger. The court affirmed the circuit court’s judgment and sentence against Milazzo. View "State v. Milazzo" on Justia Law

Melissa Moody sustained an injury while performing a push press exercise during a group class led by a trainer from Dynamic Fitness Management Ltd. at a gym in St. Louis. Moody, who had been a member of the gym since 2011, was instructed by the trainer to perform the exercise with increasing weights. After successfully completing two repetitions at 85 pounds, she felt pain during the third repetition, leading to a herniated disc and subsequent surgeries. Moody sued Dynamic for negligence, claiming the trainer failed to properly assess her fitness and supervise her during the exercise.The Circuit Court of the City of St. Louis held a jury trial, which resulted in a verdict in favor of Moody. The jury awarded her $1 million in damages, attributing 70 percent fault to Moody and 30 percent to Dynamic. Consequently, the court entered a judgment for Moody in the amount of $300,000 plus post-judgment interest. Dynamic filed a motion for a new trial, which was overruled by operation of law when the court did not rule on it within the required timeframe. Dynamic then appealed the decision.The Supreme Court of Missouri reviewed the case and affirmed the circuit court’s judgment. The court found that Dynamic failed to preserve its claims of error for appellate review, particularly because it did not file a motion for judgment notwithstanding the verdict (JNOV) as required by Rule 72.01(b). Additionally, the court held that Dynamic did not preserve its claim related to spoliation because it failed to object at trial when the adverse inference admissions were read to the jury. The court also determined that the jury instruction given did not constitute a roving commission, as it complied with the applicable Missouri Approved Instructions and was supported by sufficient evidence. View "Moody v. Dynamic Fitness Management, LTD." on Justia Law

Brian K. Heathcock was found guilty of first-degree tampering, felony resisting arrest, and tampering with a victim. In September 2018, Heathcock threw his girlfriend's cell phone out of a moving car, then drove off with her car when she exited to retrieve it. The girlfriend reported the car stolen. Heathcock was later spotted by a deputy sheriff in Warren County, leading to a high-speed chase. He was eventually found near a Walmart, where he admitted to taking the car and stealing CDs.Heathcock pleaded guilty to first-degree tampering in Montgomery County in October 2019. In November 2020, he was charged in Warren County with another count of first-degree tampering for the same vehicle incident. Heathcock moved to dismiss this count on double jeopardy grounds, but the circuit court overruled the motion. He was also charged with felony resisting arrest and tampering with a victim. A jury found him guilty on all counts, and the circuit court sentenced him to five years in prison for each count, with some sentences to be served concurrently and others consecutively. Heathcock renewed his double jeopardy objection in his motion for a new trial.The Supreme Court of Missouri reviewed the case and affirmed the circuit court's judgment. The court held that Heathcock's convictions were based on two distinct acts of tampering, as he operated the vehicle unlawfully on separate occasions. The court found that each act of operation constituted a discrete crime, and thus, did not violate double jeopardy protections. The court concluded that Heathcock's actions in Montgomery and Warren Counties were separate offenses, justifying multiple convictions. View "State v. Heathcock" on Justia Law