Justia Missouri Supreme Court Opinion Summaries

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

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