Justia Missouri Supreme Court Opinion Summaries

The case involves an injury sustained by an individual while operating a forklift designed, manufactured, and distributed by a company. The injured party alleged that the forklift’s open operator compartment constituted a defective design, making the product unreasonably dangerous, and asserted that adding features such as a door or bumper would have prevented the accident. To support these claims, the injured party retained an expert witness to testify about the alleged defect and alternative, safer designs.In the Circuit Court of Jackson County, the defendant company filed motions both to exclude the plaintiff’s expert witness and for summary judgment. The court found that the expert’s testimony lacked reliability, as the plaintiff failed to demonstrate that the expert’s opinions were based on reliable principles and methods, or that those methods had been properly applied to the facts. The court noted the absence of relevant testing, peer-reviewed support, or clear connection between the expert’s analysis and the incident. Consequently, the court excluded the expert’s testimony. Without admissible expert evidence to support the defective design claim, the circuit court then granted summary judgment for the company, as there was no genuine issue of material fact.On appeal, the Supreme Court of Missouri reviewed only the grant of summary judgment. The court held that the circuit court did not abuse its discretion in excluding the expert’s testimony under section 490.065, as the plaintiff failed to establish the reliability of the expert’s methods or their application to the case. The Supreme Court of Missouri affirmed the circuit court’s judgment, holding that without admissible expert testimony, summary judgment was proper, including as to the punitive damages claim, because the plaintiff could not prevail on the underlying product liability claim. View "Hanshaw v. Crown Equipment Corp." on Justia Law

Two women, who were never married, were granted joint guardianship of twin girls when the children were very young. After their relationship ended, they continued to share custody through the guardianship. Several years later, both women filed competing adoption petitions. The circuit court granted one woman’s petition, making her the adoptive parent and terminating the guardianship. The other woman’s appeal of the adoption was unsuccessful.While that appeal was pending, the non-adoptive woman filed a petition in the Circuit Court of Jackson County seeking third-party custody or, alternatively, visitation rights under section 452.375.5(5). The adoptive parent moved to dismiss the petition, arguing her former partner lacked standing under the statute. The circuit court denied the motion, and the parties later appeared to reach a settlement, resulting in a proposed judgment granting third-party visitation. The adoptive parent objected before the judgment was entered, but the court signed the judgment granting visitation. When the adoptive parent was found to have violated this judgment, the court awarded compensatory visitation and attorney’s fees to the other woman. The adoptive parent appealed both rulings. The Missouri Court of Appeals affirmed, concluding the non-adoptive woman had standing and that consent to the visitation agreement was binding.The Supreme Court of Missouri reviewed the case and held that section 452.375.5(5)(a) does not create an independent cause of action for third-party custody or visitation when custody is not otherwise at issue in an underlying proceeding. The Court determined that a third party may only seek custody or visitation under the statute as part of an already pending custody dispute, not as a stand-alone action following an adoption. The Supreme Court of Missouri reversed the lower court’s judgments and dismissed the petition and related family access motion. View "In re A.L.P. and S.H.P." on Justia Law

The appellant was charged with driving while intoxicated in 2021 and the state sought to enhance his sentence by establishing that he was a chronic offender, which requires proof of four or more prior intoxication-related traffic offenses (IRTOs). To support this, the state introduced evidence of four prior offenses, including a 2002 municipal conviction for “driving while intoxicated” under the Joplin city code. The appellant contested the use of this 2002 offense, arguing the evidence did not prove beyond a reasonable doubt that it involved physically driving or operating a vehicle, as required by Missouri law at the time of the current offense.The Circuit Court of Jasper County admitted the 2002 municipal conviction into evidence and found the appellant to be a chronic offender, determining all four prior offenses qualified as IRTOs. The appellant was subsequently convicted by a jury for the current driving while intoxicated offense and sentenced as a chronic offender to seven years’ imprisonment. He appealed, arguing that only three of his prior offenses qualified as IRTOs and that he should have been sentenced as an aggravated offender rather than a chronic offender.The Supreme Court of Missouri reviewed the sufficiency of the evidence de novo. It held that the state failed to prove beyond a reasonable doubt that the 2002 municipal offense involved physically driving or operating a vehicle, since the record was silent as to the conduct underlying the offense and there was no evidence as to the elements of the municipal ordinance. Consequently, the court vacated the judgment sentencing the appellant as a chronic offender and remanded the case for resentencing as an aggravated offender. View "State v. Peters" on Justia Law

Late at night, a police officer in Jefferson City observed a vehicle behaving suspiciously in a closed business area known for crime. The officer stopped the vehicle, which was driven by James Eggleston with a female passenger. The passenger appeared to be under the influence of narcotics, and Eggleston volunteered that he had an outstanding warrant and did not consent to a search of the vehicle. After arresting Eggleston, the officer contacted a canine unit. The canine alerted to the driver's side, leading officers to search the vehicle and find a bottle containing four baggies of methamphetamine within easy reach of the driver's seat. Additional drug paraphernalia and the passenger’s identification were found on the passenger side.The State charged Eggleston with possession of a controlled substance in violation of Missouri law. Following a bench trial in the Circuit Court of Cole County, the judge found Eggleston guilty and sentenced him to three years in prison. Eggleston appealed, arguing that the evidence was insufficient to prove he knowingly possessed the methamphetamine, particularly since it was in a shared compartment and could have belonged to the passenger.The Supreme Court of Missouri reviewed the case, applying the statutory definitions of “knowingly” and “possessed” and clarifying that joint possession does not require “additional incriminating evidence” beyond proximity and control. The court held that circumstantial evidence, including the methamphetamine’s location within Eggleston’s reach, his conduct, and other contextual facts, was sufficient for a rational factfinder to conclude he knowingly possessed the controlled substance. The Supreme Court of Missouri affirmed the circuit court’s judgment, holding that the conviction was supported by sufficient evidence and rejecting prior case law that imposed heightened burdens in joint possession cases. View "State of Missouri vs. Eggleston" on Justia Law

Amanda Rogers was convicted of unlawful possession of a firearm by a felon after an incident in which she drove a vehicle with a passenger, Seller, who attempted to sell a gun to Informant. Informant notified law enforcement after Seller, a known felon, tried to sell him a firearm and could not provide proof of ownership. Rogers drove Seller to meet Informant; after the attempted sale, Informant described the vehicle, its occupants, and its direction to law enforcement. Trooper Enderle located the vehicle, initiated a stop after backup arrived, and found Rogers acting suspiciously. A subsequent search revealed compatible ammunition on the driver’s side and a firearm within easy reach of both front seats. Rogers denied knowledge of a firearm and refused consent to search. After a canine unit arrived, law enforcement found the firearm in a bucket between the seats.The Circuit Court of Polk County, following a jury verdict of guilty, sentenced Rogers to seven years’ imprisonment and placed her in a long-term treatment program. Rogers moved to suppress the firearm and ammunition, arguing lack of probable cause for the stop and insufficient evidence of knowing possession. The circuit court denied both motions. She appealed, raising the same issues, and the Missouri Court of Appeals reviewed the case before the Supreme Court of Missouri granted transfer.The Supreme Court of Missouri held that the state presented sufficient evidence for a reasonable factfinder to conclude Rogers knowingly possessed the firearm, applying statutory definitions of possession and knowledge, and rejected the requirement for “additional incriminating evidence” in joint possession cases. The Court also found that Trooper Enderle had probable cause to search the vehicle, based on Informant’s tip, corroborating circumstances, and Rogers’ conduct. The judgment of the circuit court was affirmed. View "State of Missouri vs. Rogers" on Justia Law

The appellant brought a defamation action against two individuals, with whom he had prior romantic relationships. After those relationships ended, one defendant told others that the appellant had raped and abused her, while the other engaged in a broad social media campaign accusing the appellant of stalking, rape, threats, and violent behavior. These statements led to significant consequences for the appellant, including being confronted at his home by an armed group, being forced to leave his residence for months, being excluded from a local coffee shop, losing organizational affiliations and a speaking engagement, and being removed from shared office space.The case was first heard in the Circuit Court of St. Louis County. At the close of the appellant’s evidence, both defendants moved for directed verdicts, arguing that the appellant had failed to present evidence of reputational harm independent of his own testimony. The circuit court sustained the motions and entered judgment for the defendants, apparently on that sole ground. Four counts against one defendant related to agency were also dismissed; the appellant later abandoned those claims on appeal.The Supreme Court of Missouri reviewed the case. It held that a plaintiff in a defamation action is not required to provide independent evidence of reputational harm, and that credible testimony by the plaintiff may suffice if it establishes actual injury to reputation. The court found that the appellant’s testimony regarding the consequences of the defendants’ statements was sufficient for a reasonable jury to find reputational damage. The judgment in favor of the defendants was affirmed with respect to the abandoned agency-based counts, but was vacated as to all other counts. The case was remanded for a new trial on those remaining claims. View "Apperson v. Kaminsky" on Justia Law

Two homeowners purchased a lot in a subdivision that was subject to restrictive covenants, including one prohibiting the installation of solar panels on residences. After their purchase, Missouri’s legislature enacted a statute barring covenants or restrictions that limit or prohibit solar panel installations on rooftops. The homeowners attempted to work with their homeowners’ association to amend the restriction, but the association maintained the ban, later offering only limited permission for panels not visible from the street. The homeowners then sought declaratory and injunctive relief, challenging the enforceability of the covenant and the association’s rule on street-facing panels.The Circuit Court of Greene County denied relief to the homeowners, ruling that the new statute applied only to covenants created after its effective date and that applying it to preexisting covenants would impermissibly impair the contractual rights established before the statute’s enactment. The court found that retrospective application of the law was unconstitutional under Missouri’s constitution.On appeal, the Supreme Court of Missouri reviewed the judgment de novo. The Court held that the legislative intent and the statute’s language supported applicability to all covenants, including those enacted before the statute’s effective date. The Court determined that, while the statute operates prospectively, it renders prior prohibitions unenforceable from the effective date forward, without violating constitutional prohibitions against retrospective laws or impairing contracts. The Court found that the association’s rule prohibiting street-facing solar panels adversely affected cost and efficiency and could not be enforced under the statute.The Supreme Court of Missouri reversed the judgment of the Circuit Court, entered judgment for the homeowners, and held that both the covenant banning solar panels and the rule prohibiting street-facing panels were unenforceable under section 442.404.3. View "Eikmeier v. Granite Springs Home Owners Association, Inc." on Justia Law

After the Missouri General Assembly enacted Senate Bill No. 22 (SB 22) in 2025, which made several changes to statutes governing ballot summaries and judicial proceedings, a Missouri resident and taxpayer challenged its constitutionality. SB 22 as introduced focused solely on amending the process for judicial review of ballot summary statements. During the legislative process, SB 22 was amended to include provisions expanding the attorney general’s authority to appeal certain preliminary injunctions, a subject unrelated to ballot summaries, and the bill’s title was changed from “relating to ballot summaries” to “relating to judicial proceedings.” After passage by both legislative chambers and the Governor’s signature, the bill became law.The Circuit Court of Cole County reviewed the case after the plaintiff alleged SB 22 violated the Missouri Constitution’s original purpose, single subject, and clear title requirements, as well as equal protection guarantees. The circuit court found the bill did not violate the procedural constitutional provisions, but it did find that the amendment to section 526.010 (concerning the attorney general’s appellate rights) violated equal protection and was severable from the rest of the bill. The court allowed the remaining portions, primarily those addressing ballot summaries, to stand. The plaintiff appealed, challenging the findings on the procedural requirements, while the State cross-appealed on standing and equal protection.The Supreme Court of Missouri heard the case and held that the plaintiff had taxpayer standing because SB 22’s provisions resulted in a direct expenditure of public funds. Upon de novo review, the Supreme Court found that SB 22 violated the original purpose requirement of article III, section 21 of the Missouri Constitution because the added provision regarding the attorney general’s appellate rights was not germane to the bill’s original purpose. The Court further held that the offending provision could not be severed, and therefore invalidated SB 22 in its entirety, reversing the judgment of the circuit court. View "Nicholson v. State" on Justia Law

Craig M. Wood was convicted of abducting and murdering 10-year-old Hailey Owens in Springfield, Missouri. After eyewitnesses reported the abduction and provided Wood’s license plate number, police traced it to Wood's residence. Upon searching his home, officers found Hailey’s body in the basement, along with evidence of sexual assault and materials indicating Wood’s sexual interest in young girls. Wood was tried and found guilty of first-degree murder and sentenced to death.The Circuit Court of Greene County presided over Wood’s jury trial, entered judgment, and imposed the death sentence after the jury found multiple aggravating circumstances. The Supreme Court of Missouri previously affirmed Wood’s conviction and sentence on direct appeal in State v. Wood, 580 S.W.3d 566 (Mo. banc 2019). Wood then filed a Rule 29.15 motion for postconviction relief, arguing ineffective assistance of counsel on numerous grounds related to evidence, trial strategy, and mitigation. The motion court held an evidentiary hearing and denied the motion, finding no basis for relief.On appeal to the Supreme Court of Missouri, Wood raised 22 points concerning counsel’s performance and other alleged errors. The court reviewed whether the motion court’s findings and conclusions were clearly erroneous, applying the standard set forth in Rule 29.15(k). The Supreme Court of Missouri held that none of Wood’s claims demonstrated deficient performance or prejudice under the Strickland v. Washington standard. The court found the motion court’s factual determinations and legal conclusions were not clearly erroneous and affirmed the denial of postconviction relief. The judgment overruling Wood’s Rule 29.15 motion was affirmed. View "Wood vs. State of Missouri" on Justia Law

The Missouri General Assembly enacted two statutes effective August 28, 2023: the SAFE Act, which generally prohibits health care providers from performing gender transition surgeries or prescribing cross-sex hormones and puberty-blocking drugs for minors, and the Medicaid ban, which precludes MO HealthNet payments for such treatments when used for gender transition. The statutes include specific exemptions, such as for treatment of certain medical conditions and for minors already receiving such care prior to enactment. E.N., on behalf of her minor child and joined by medical professionals and organizations, challenged both laws, alleging violations of equal protection, due process, and the gains of industry clause under the Missouri Constitution.The Circuit Court of Cole County conducted a two-week bench trial and entered judgment in favor of the State, upholding the constitutionality of both statutes. The court found the challengers had raised only facial challenges and determined that neither statute violated the constitutional provisions cited. The challengers appealed, raising multiple points of error regarding the constitutional analysis and factual findings at trial.The Supreme Court of Missouri reviewed the circuit court’s determination de novo, applying a presumption of constitutionality. Relying on recent decisions from the United States Supreme Court and the United States Court of Appeals for the Eighth Circuit, the court held that both statutes classify based only on age and medical use, not on sex or transgender status. Thus, rational-basis review applied. The court found that the statutes are rationally related to legitimate state interests, such as safeguarding minors and managing public resources, and do not infringe fundamental rights. The court affirmed the circuit court’s judgment, concluding that the challengers failed to demonstrate any constitutional violation. View "E.N. v. Kehoe" on Justia Law