Justia Missouri Supreme Court Opinion Summaries

In August 2025, the governor of Missouri issued a proclamation calling for an extraordinary legislative session. The session was convened to address two issues: establishing new congressional districts and changing the initiative petition process. The governor explained that the legislature had adjourned without enacting new district boundaries, which could expose the state to legal challenges, and that changes to the initiative petition process were needed to address concerns about foreign influence and voter confusion. During this extraordinary session, the legislature passed a new congressional map and proposed a constitutional amendment related to initiative petitions.On the day the session was to begin, the NAACP and two individuals filed suit in the Circuit Court of Cole County, seeking a declaration that the governor’s proclamation did not state an “extraordinary occasion” as required by article IV, section 9 of the Missouri Constitution. They also sought to enjoin the session and later the implementation of the enacted measures. The circuit court, after a bench trial, ruled in favor of the state officials, finding that the governor had constitutional authority to call the extraordinary session and that the question was a political one, best decided by the governor.The Supreme Court of Missouri, reviewing the circuit court’s declaratory judgment, affirmed the decision. The court held that article IV, section 9 vests the governor with discretion to determine when an extraordinary occasion has arisen and to call an extraordinary session accordingly. The court rejected the argument that the governor’s discretion is limited by an objective definition of “extraordinary,” finding that neither the constitutional text nor its historical context imposed such a restriction. The judgment of the Circuit Court of Cole County was affirmed. View "National Association for the Advancement of Colored People Missouri State Conference vs. Kehoe" on Justia Law

James Guthrie was charged with multiple counts of sexual offenses involving two victims. Relevant to this appeal, one count alleged that Guthrie committed first-degree statutory rape against Victim 2, specifically that he knowingly had sexual intercourse with her when she was less than fourteen years old. At trial, Victim 2 testified that the incident occurred in 2017, and though she initially indicated it happened when she was 14, she also described herself as a “preteen” at the time. The defense argued that the evidence was insufficient to prove the offense took place before Victim 2 turned fourteen.After a jury trial in the Circuit Court of Mississippi County, Guthrie was found guilty on all counts. He appealed, contending that the evidence did not establish beyond a reasonable doubt that Victim 2 was under fourteen when the offense occurred. The Missouri Court of Appeals initially reviewed the case, and then the Supreme Court of Missouri accepted transfer and exercised jurisdiction.The Supreme Court of Missouri held that, under the standard requiring the court to view evidence and reasonable inferences in the light most favorable to the verdict, the jury was permitted to credit Victim 2’s testimony that she was a “preteen” at the time of the incident, which by definition means younger than thirteen. The Court found that this testimony provided sufficient evidence that the crime occurred before Victim 2 turned fourteen, as required by statute. The Court rejected arguments that conflicting testimony or the lack of precise dates undermined the verdict, and it noted that no due process or instructional challenges were preserved. Accordingly, the Supreme Court of Missouri affirmed the conviction and the judgment of the circuit court. View "State vs. Guthrie" on Justia Law

After the Missouri legislature enacted a new congressional redistricting map in 2025, two groups of residents challenged its constitutionality. The residents argued that the map violated article III, section 45 of the Missouri Constitution, which requires congressional districts to be comprised of contiguous territory, to be as compact as possible, and to have nearly equal populations. Their claims focused particularly on districts 4, 5, and 6, alleging lack of compactness, improper splitting of Kansas City communities, and that a voting tabulation district (KC 811) was assigned to two congressional districts, violating contiguity and equal population requirements.The Circuit Court of Jackson County consolidated the two cases and held a bench trial. After reviewing extensive expert and lay testimony, statistical measures of compactness, and evidence regarding county and municipal splits, the circuit court found that the 2025 Map was more compact than prior maps, satisfied contiguity and equal population requirements, and did not violate the constitutional standards. The circuit court rejected claims regarding community splits and alternative maps, emphasizing its role was not to weigh policy preferences but to apply constitutional directives.On appeal, the Supreme Court of Missouri reviewed the circuit court’s factual findings with deference and applied de novo review to legal questions. The Court held that the plaintiffs failed to demonstrate the 2025 Map clearly and undoubtedly violated article III, section 45. The Court emphasized that statistical and historical comparisons supported the circuit court’s findings, and that departures from compactness, if any, were minimal and justified by recognized factors. The Supreme Court of Missouri affirmed the circuit court’s judgment, upholding the constitutionality of the 2025 Map. View "Healey vs. State" on Justia Law

In September 2025, the Missouri General Assembly enacted HB 1, which redrew congressional districts despite no new census certification. Two Missouri voters, affected by the redistricting, signed and helped submit a referendum petition to challenge HB 1 before it took effect in December 2025. They argued that upon filing the petition with the secretary of state on December 9, 2025, HB 1 was automatically suspended under the Missouri Constitution until voters could decide on it. They also contended that any statutes allowing the secretary to delay suspension until official verification conflicted with constitutional provisions.The Circuit Court of Cole County held a bench trial on stipulated facts. It dismissed the voters’ petition on several grounds—lack of standing, lack of ripeness, the political question doctrine, and the existence of an adequate statutory remedy. On the merits, it also declared that filing the referendum petition did not automatically suspend HB 1. The voters appealed, and the Supreme Court of Missouri accepted transfer to review the important legal question presented.The Supreme Court of Missouri held that simply filing a referendum petition does not automatically suspend a legislative act under article III, sections 49, 52(a), or 52(b) of the Missouri Constitution. The Court reasoned that such suspension only occurs if the referendum petition is ultimately determined to be legal, sufficient, and timely, as required by constitutional and statutory provisions. The ongoing statutory process for verifying signatures and certification by the secretary of state must be completed to determine sufficiency. The Court also rejected the argument that the relevant statutes were unconstitutional as applied. The judgment of the circuit court was affirmed. View "Maggard vs. State" on Justia Law

A dispute arose over the 2016 property tax assessment for a hotel located at Kansas City International Airport. Grady Hotel Investments, LLC purchased the hotel improvements but not the land, which remained owned by the City of Kansas City. As the City is exempt from property taxes, Grady was taxed only on its possessory interest in the hotel improvements. The Platte County assessor valued the property at over $11 million, which was raised to more than $13 million by the Platte County Board of Equalization. On appeal, a State Tax Commission (STC) hearing officer reduced the value, and the full STC ultimately valued it at $0, using a method applicable to leaseholds. The assessor challenged this, and the circuit court found the STC’s valuation method inapplicable, determining Grady owned the improvements rather than holding a leasehold.The Missouri Court of Appeals affirmed the circuit court’s conclusion that Grady held an ownership interest, not a mere leasehold, and remanded the case for a new valuation. On remand, the STC valued the property at over $6 million. The assessor and Park Hill School District appealed, raising constitutional challenges to the valuation statute, section 137.115.1, arguing it violated provisions of the Missouri Constitution related to due process, tax exemptions, uniformity, and special privileges.The Supreme Court of Missouri reviewed the case. It held that Park Hill School District lacked standing to challenge the assessment, as its interest in potential funding loss did not confer standing to contest another’s property valuation. The assessor also lacked standing to assert claims under due process and special privilege provisions because, as a political actor, he was not protected by those constitutional rights. However, the assessor did have standing to challenge the statute under the tax exemption and uniformity provisions. The court held that section 137.115.1 neither creates an unconstitutional tax exemption nor violates the uniformity clause. The circuit court’s judgment was affirmed. View "Cox vs. Grady Hotel Investments, LLC" on Justia Law

After his employment as a wet plant foreman was terminated in January 2022, the plaintiff sent a certified letter in April 2022 to his former employer, requesting a service letter as required by Missouri law. He did not receive a response. The plaintiff later filed suit against the company, alleging a violation of section 290.140 for failure to provide the service letter. He also initially included a claim for disability discrimination under the Americans with Disabilities Act, but that claim was dismissed in federal court, and the remaining statutory claim was remanded to state court.The Circuit Court of Cape Girardeau County granted summary judgment to the defendant company. The defendant had argued that the plaintiff’s service letter request and lawsuit were directed at the wrong corporate entity, asserting that another related company had actually employed the plaintiff. The plaintiff failed to properly respond to the summary judgment motion as required by Rule 74.04(c)(2), instead making bulk admissions and denials without specific references to the record. Because of this failure, the court deemed the defendant’s factual statements admitted and found no genuine issue of material fact. The plaintiff appealed, and the Supreme Court of Missouri granted transfer after an opinion by the court of appeals.The Supreme Court of Missouri held that summary judgment is not an “extreme or drastic remedy” and reaffirmed the requirements for summary judgment motions and responses under Missouri law. The Court concluded that, because the plaintiff did not properly preserve or raise any arguments demonstrating error by the circuit court, and failed to comply with procedural rules, there was no basis to overturn the grant of summary judgment. The judgment of the circuit court in favor of the defendant was affirmed. View "Wilkinson vs. Farmers Holding Companies" on Justia Law

Several individuals and two organizations challenged a Missouri law enacted in 2022, House Bill No. 1878 (HB 1878), which amended the state’s voting requirements by mandating that voters present specific forms of photo identification or cast a provisional ballot under certain conditions. The organizations—the Missouri State Conference of the NAACP and the League of Women Voters of Missouri—along with the individuals, claimed that these provisions unconstitutionally burdened the right to vote and violated equal protection guarantees.Their petition for declaratory and injunctive relief was filed in the Circuit Court of Cole County. After a bench trial, the circuit court found that none of the individual plaintiffs had shown an actual or threatened injury, as each had either successfully voted since the law’s enactment or their alleged difficulties were speculative. The court also determined that the organizations had not established standing, either through a diversion of resources or by identifying any specific member adversely affected by the law. Despite these findings, the circuit court proceeded to rule on the merits, concluding the law was constitutional.The Supreme Court of Missouri, which has exclusive jurisdiction in cases involving the validity of state statutes, reviewed the matter. The Supreme Court affirmed the circuit court’s determination that the appellants lacked standing—meaning none of the plaintiffs demonstrated a concrete, personal stake in the outcome. The Supreme Court held that, because there was no justiciable controversy before the court, the circuit court erred by reaching and deciding the merits of the constitutional claims. Therefore, the Supreme Court reversed that portion of the judgment addressing the merits of the constitutional challenge. The case was thus resolved solely on the issue of standing. View "Missouri State Conference of the National Association for the Advancement of Colored People vs. State" on Justia Law

In 2022, Missouri enacted new legislation that imposed several restrictions on activities related to voter registration and absentee ballot applications. The law prohibited the payment or compensation of individuals for soliciting voter registration applications unless they were government employees, required anyone who solicited more than ten voter registration applications to register with the state, and mandated that solicitors be at least eighteen years old and registered Missouri voters. Additionally, the law completely banned the solicitation of voters to obtain absentee ballot applications. These provisions affected organizations whose work involves encouraging and assisting individuals in registering to vote and informing them about absentee voting.The Circuit Court of Cole County reviewed a lawsuit brought by two civic organizations challenging these provisions as unconstitutional. The organizations argued the restrictions violated rights to free speech, association, and due process under the Missouri Constitution. The court issued a preliminary injunction, and after trial, permanently enjoined enforcement of the provisions, finding them to be facially unconstitutional restrictions on core political speech, overbroad, content- and viewpoint-based, and unconstitutionally vague. The court concluded the state had not shown the provisions were narrowly tailored to serve a compelling governmental interest.On direct appeal, the Supreme Court of Missouri affirmed the circuit court’s judgment. The Supreme Court of Missouri held that the statutory provisions imposed facially unconstitutional restrictions on core political speech protected by article I, section 8 of the Missouri Constitution. The Court found the provisions neither served a compelling state interest nor were narrowly tailored, and instead captured substantial amounts of protected speech unrelated to any compelling interest. The judgment declaring the provisions unconstitutional was affirmed. View "State vs. League of Women Voters" on Justia Law

After the results of the 2020 United States census were certified to the governor of Missouri in August 2021, the Missouri General Assembly established new congressional districts in 2022, as required by the state constitution. In September 2025, the General Assembly passed House Bill 1 (“HB 1”), which repealed the 2022 congressional districts and established new ones, even though no new census had been certified. The governor signed HB 1 into law. A group of plaintiffs challenged the constitutionality of HB 1, arguing that article III, section 45 of the Missouri Constitution restricts the General Assembly to one redistricting following each decennial census certification.The Circuit Court of Cole County heard the case on stipulated facts and rejected the plaintiffs’ claim, finding that HB 1 was a valid exercise of the General Assembly’s legislative authority. The circuit court declared that article III, section 45 does not prevent the General Assembly from redistricting more frequently than once per decade.On appeal, the Supreme Court of Missouri reviewed the constitutional question de novo. The Court held that article III, section 45 obligates the General Assembly to redistrict upon certification of the decennial census but does not expressly prohibit mid-decade or more frequent congressional redistricting. The Court explained that, absent express constitutional restraint, the General Assembly’s legislative power remains plenary. The Court also found that the word “when” in section 45 acts as a trigger for mandatory redistricting but does not serve as a limitation on the legislature’s authority to redistrict at other times.The Supreme Court of Missouri affirmed the circuit court’s judgment, upholding HB 1 as constitutional and concluding that article III, section 45 does not restrict the General Assembly’s power to conduct mid-decade congressional redistricting. View "Luther vs. Hoskins" on Justia Law

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