Justia Missouri Supreme Court Opinion Summaries

Diana Penney, a pharmacy technician from 1980 to 2019, filed multiple work-related occupational disease claims due to repetitive activities at her job. She was diagnosed with low back issues, protruding disks in her neck and upper back, and carpal tunnel syndrome. Penney underwent surgeries and stopped working in August 2019 due to pain from these conditions. She sought permanent total disability (PTD) benefits from the Second Injury Fund (the Fund).An administrative law judge (ALJ) concluded that Penney was permanently and totally disabled due to the combined effect of her occupational diseases and awarded her PTD benefits from the Fund. The Fund appealed to the Labor and Industrial Relations Commission, arguing that the ALJ improperly considered Penney’s preexisting occupational diseases under the relevant statutory category. The Commission disagreed and affirmed the ALJ’s award.The Supreme Court of Missouri reviewed the case and held that preexisting occupational diseases do not qualify as preexisting disabilities under section 287.220.3(2)(a)a(ii)1, which requires the disability to be a “direct result of a compensable injury as defined in section 287.020.” The court noted that section 287.020 encompasses injuries by accident and explicitly excludes occupational diseases. The court emphasized that the legislature’s choice to reference only section 287.020 in the statute indicates an intent to limit qualifying preexisting disabilities to accidental injuries. Consequently, the court reversed the Commission’s decision, ruling that Penney’s preexisting occupational diseases could not be considered in determining her entitlement to PTD benefits from the Fund. View "Treasurer v. Penney" on Justia Law

James Eckardt, an aircraft mechanic, sustained multiple work-related injuries over his 40-year career, including injuries to his knees, shoulders, wrists, and cervical spine. His final injury occurred in October 2015, leading to a spinal fusion surgery. Eckardt retired in February 2017 due to his inability to perform his job duties and sought permanent total disability (PTD) benefits from the Treasurer of Missouri as Custodian of the Second Injury Fund.An administrative law judge (ALJ) in the Division of Workers’ Compensation assigned permanent partial disability (PPD) amounts to Eckardt’s preexisting injuries and determined he was permanently and totally disabled, awarding PTD benefits. The Fund appealed to the Labor and Industrial Relations Commission, arguing that the ALJ improperly considered non-qualifying injuries, including carpal tunnel syndrome and a right shoulder injury, in the PTD determination. The Commission reversed the ALJ’s decision, finding that the doctor’s reliance on the non-qualifying right shoulder injury meant there was no credible evidence that Eckardt was permanently and totally disabled due to the primary injury in combination with only qualifying preexisting injuries.The Supreme Court of Missouri reviewed the case and affirmed the Commission’s denial of PTD benefits. The Court held that Eckardt’s right shoulder injury did not qualify as a preexisting disability because it did not meet the statutory threshold of 50 weeks PPD, and a load factor could not be applied to enhance the PPD amount. The Court also found that Eckardt failed to show he was permanently and totally disabled due to the combination of his primary injury and only his qualifying preexisting disabilities, as the doctor’s opinion improperly included the non-qualifying right shoulder injury. Therefore, Eckardt did not meet his burden of proof for Fund liability, and his claim for PTD benefits was denied. View "Eckardt v. Treasurer" on Justia Law

Trent Berhow, while incarcerated at Western Missouri Correctional Center, fell from a ladder and subsequently filed a lawsuit against the state of Missouri, alleging that his supervisor's instructions created a dangerous condition leading to his injury. Berhow filed his suit more than a year after the incident, which brought into question the statute of limitations.Initially, Berhow sued the Missouri Department of Corrections. The department moved to dismiss the petition, citing the statute of limitations. Berhow then amended his petition to dismiss the department and add the state as the defendant. The Circuit Court of DeKalb County overruled the state's first motion for judgment on the pleadings but later sustained the state's renewed motion, which argued both sovereign immunity and the statute of limitations. Berhow's motion for sanctions was also effectively overruled by the circuit court.The Supreme Court of Missouri reviewed the case de novo. The court held that Berhow's claim was barred by the statute of limitations under section 516.145, which requires actions against the Department of Corrections or any entity thereof to be brought within one year. The court reasoned that allowing Berhow to sue the state instead of the department would defeat the purpose of the statute, as the department acts on the state's behalf. The court affirmed the circuit court's judgment, concluding that the statute of limitations barred Berhow's claim. View "Berhow v. State" on Justia Law

Robert J. Branson was charged with six sex crimes, including three unclassified felonies, for raping and sodomizing a child. On the day of the trial, Branson negotiated an Alford plea to one count of first-degree child molestation (class A felony) and two counts of second-degree statutory rape. The State amended the charges accordingly. During the plea hearing, Branson acknowledged he was charged with a class A felony and faced a potential life sentence. The circuit court accepted his plea and sentenced him to life imprisonment for the class A felony and consecutive seven-year terms for the two counts of second-degree statutory rape.Branson filed a Rule 24.035 motion for postconviction relief but did not allege a factual defect in his guilty plea or that his sentence exceeded the statutory maximum. The circuit court overruled the motion. On appeal, Branson claimed for the first time that the State failed to allege the necessary facts for a class A felony. The court of appeals affirmed the judgment, holding that Branson waived this argument by not raising it in his Rule 24.035 motion.Branson then filed a petition for a writ of habeas corpus, alleging his sentence was excessive because the factual basis for his guilty plea only supported a class B felony. The circuit court denied the petition, but the court of appeals granted it. The Supreme Court of Missouri reviewed the case and denied habeas relief, holding that Branson waived his sentencing claim by not raising it in his Rule 24.035 motion. The court found no jurisdictional defect, cause and prejudice, or manifest injustice warranting habeas review of the procedurally defaulted claim. The court overruled previous cases that allowed habeas review for sentencing errors as jurisdictional defects. View "Branson v. Shewmaker" on Justia Law

Registered Missouri voters Raymond McCarty, Daniel Shaul, Russell Lahl, and Michael Hastings, along with several nonprofit organizations, contested the results of the November 2024 election approving Proposition A. They argued that the summary statement and fiscal note summary for Proposition A were misleading, casting doubt on the election's fairness and validity. Proposition A proposed increasing the minimum wage, adjusting it based on the Consumer Price Index, requiring paid sick leave, and exempting certain entities.The Missouri Supreme Court reviewed the case. The lower courts had not previously reviewed this specific election contest. The plaintiffs brought the case directly to the Missouri Supreme Court, which has original jurisdiction over election contests under chapter 115 of the Missouri statutes.The Missouri Supreme Court held that the summary statement and fiscal note summary for Proposition A were not misleading or materially inaccurate. The court found that the summary statement fairly and impartially summarized the central features of Proposition A, and the fiscal note summary adhered to statutory requirements by focusing on governmental costs. The court concluded that there was no election irregularity of sufficient magnitude to cast doubt on the election's validity. Additionally, the court dismissed the plaintiffs' claims that Proposition A violated the "single subject" and "clear title" requirements of the Missouri Constitution, citing a lack of original jurisdiction over these claims. The court upheld the election results, affirming the validity of Proposition A. View "McCarty v. Secretary of State" on Justia Law

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