Justia Missouri Supreme Court Opinion Summaries

In the early morning, a police officer stopped Chad Thomas for driving with a broken headlight. During the stop, Thomas exhibited unusual behavior, such as rolling down the rear window instead of the front, being unable to find his driver’s license, and acting nervously. The officer conducted a pat-down search, during which Thomas mentioned he might have a "sharp," a term the officer associated with drug use. Thomas's behavior, including blocking the officer's view and lying about having his license, led the officer to call for a canine unit, which eventually alerted to the presence of drugs.The Circuit Court of Saline County overruled Thomas's motion to suppress the evidence found during the search, concluding that the officer had reasonable suspicion to extend the stop based on Thomas's behavior. The court found that the extension of the stop was justified by Thomas's actions and the need to verify his identity and the outstanding warrant. The court admitted the evidence, and the jury found Thomas guilty of possession of a controlled substance and unlawful possession of drug paraphernalia. Thomas was sentenced to 10 years in prison.The Supreme Court of Missouri reviewed the case and affirmed the circuit court’s judgment. The court held that the officer had reasonable suspicion to extend the traffic stop based on the totality of Thomas's behavior, which included nervousness, evasive actions, and inconsistent statements. The court found that the detention and subsequent search were lawful under the Fourth Amendment, as the officer's actions were justified by reasonable suspicion of criminal activity. View "State vs. Thomas" on Justia Law

Jessica Goodman, the Saline County Assessor, filed a lawsuit seeking a declaration regarding the correct classification of Saline County under Missouri law. Goodman argued that Saline County should be classified as a third-class county based on its assessed valuation over five years, rather than its current classification as a second-class county. The County moved to dismiss the petition, arguing that the statute in question, section 48.020.1, exempts Saline County from reclassification regardless of changes in assessed valuation.The Circuit Court of Saline County dismissed Goodman’s petition. Goodman appealed the decision to the Missouri Court of Appeals, Western District. The Court of Appeals transferred the case to the Supreme Court of Missouri, believing that the case involved the validity of a state statute, which would fall under the Supreme Court's exclusive jurisdiction.The Supreme Court of Missouri determined that it did not have exclusive appellate jurisdiction because Goodman did not properly raise a constitutional challenge to the statute in question. Goodman’s arguments against the County’s interpretation of the statute did not amount to a direct claim that the statute was unconstitutional. As a result, the Supreme Court of Missouri retransferred the case back to the Missouri Court of Appeals, Western District, for further proceedings. View "Goodman vs. Saline County Commission" on Justia Law

Richard Emery was convicted of four counts of first-degree murder and sentenced to death for each count. Emery admitted to killing his girlfriend K.K., her mother J.M., and K.K.'s two children, Z.K. and J.K., but argued he did not deliberate before the murders. The jury rejected this argument, finding overwhelming evidence of deliberation. Emery appealed, claiming errors in jury selection, evidence admission, the prosecutor's closing argument, and alleged religious bias by the judge.The Circuit Court of St. Charles County struck a potential juror for cause, admitted body-camera footage and testimony about Emery's shootout with police and attempted carjacking, and allowed victim impact testimony from the officers and a carjacking victim during the penalty phase. Emery's objections to these decisions were overruled. The court found the evidence of deliberation compelling, noting Emery's methodical actions before and after the murders, including his calm demeanor and attempts to escape.The Supreme Court of Missouri reviewed Emery's claims and found no abuse of discretion or plain error. The court held that the body-camera footage and testimony about the shootout and carjacking were relevant to proving deliberation and providing a complete picture of the events. The court also found that the victim impact testimony was permissible under Missouri law. The prosecutor's closing argument did not constitute improper personalization, and the judge's comments about Emery's lack of spirituality were not indicative of religious bias.The court conducted an independent proportionality review and concluded that the death sentences were not imposed under the influence of passion, prejudice, or any other arbitrary factor. The evidence supported the jury's finding of statutory aggravating circumstances, and the sentences were not excessive or disproportionate compared to similar cases. The Supreme Court of Missouri affirmed the judgment of the Circuit Court. View "State v. Emery" on Justia Law

In 1998, the defendant fatally stabbed the victim during a burglary. The victim's belongings were found in the defendant's vehicle, and two witnesses testified that the defendant confessed to the crime. In 2001, a jury convicted the defendant of first-degree murder and other charges, sentencing him to death. Over the next 23 years, the defendant's claims of actual innocence and constitutional errors were repeatedly rejected by state and federal courts.The defendant's direct appeal was denied by the Missouri Supreme Court in 2003, and his post-conviction relief appeal was denied in 2005. The federal district court initially granted habeas relief, but the Eighth Circuit reversed this decision in 2012. The U.S. Supreme Court denied certiorari in 2013. Subsequent habeas petitions and requests for DNA testing were also denied by the Missouri Supreme Court and the U.S. Supreme Court.The Missouri Supreme Court reviewed the case and affirmed the lower court's judgment. The court found no clear and convincing evidence of actual innocence or constitutional error that would undermine confidence in the original judgment. The court noted that recent DNA testing did not support the defendant's claim of innocence and that the evidence showed the killer wore gloves, which aligned with the trial testimony. The court also rejected claims of ineffective assistance of counsel and Batson violations, as these issues had been previously adjudicated and found to be without merit.The Missouri Supreme Court affirmed the circuit court's judgment, denying the motion to vacate or set aside the conviction and sentence. The court held that the defendant failed to demonstrate actual innocence or constitutional error by clear and convincing evidence. The motion for a stay of execution was overruled as moot. View "Prosecuting Attorney, 21st Judicial Circuit, ex rel. Williams v. State of Missouri" on Justia Law

The case involves a dispute over the form and procedural requirements of an initiative petition for Amendment 3, which aims to protect reproductive freedom. The Attorney General and the Secretary of State had approved the form of the petition in March 2023. Proponents of the amendment collected the necessary signatures, and the Secretary of State certified the petition for the 2024 general election ballot. Opponents challenged the certification, claiming the petition failed to include all constitutional provisions and statutes that might be affected if the amendment were approved.The Circuit Court of Cole County ruled in favor of the opponents, finding that the petition did not meet the requirements of article III, section 50 of the Missouri Constitution and section 116.050.2(2). The court ordered the amendment removed from the ballot. Proponents appealed, and the case was transferred to the Supreme Court of Missouri.The Supreme Court of Missouri reversed the circuit court's decision. The court held that article III, section 50 requires a petition proposing a constitutional amendment to identify only those existing sections of the constitution that are in direct conflict with the proposed amendment. The court found that Amendment 3 did not purport to repeal any existing constitutional provision and was not in direct conflict with any existing constitutional article or section. The court also rejected the opponents' claim that Amendment 3 violated the "single subject" requirement, finding that all provisions of the amendment related to the single subject of protecting reproductive freedom.The court concluded that the Secretary of State's certification of Amendment 3 was correct and ordered the amendment to be placed on the 2024 general election ballot. View "Coleman v. Ashcroft" on Justia Law

Phillip Weeks filed a lawsuit against the City of Webster Groves and St. Louis County, alleging violations of Missouri’s Sunshine Law for failing to produce public records he requested. Weeks sought raw data files from vehicle stop forms, including officer identification numbers (DSNs), for specific years. Webster Groves and St. Louis County, which use the Regional Justice Information Services (REJIS) for data storage, did not fully comply with his requests. Webster Groves claimed the Sunshine Law did not require creating new records, while St. Louis County initially provided some data but later redacted the DSNs, arguing they were exempt from disclosure.The Circuit Court of St. Louis County granted summary judgment in favor of Webster Groves and St. Louis County. The court found that the DSNs were not responsive to Weeks' requests and that the Sunshine Law did not require the creation of new records. Additionally, St. Louis County argued that the DSNs were exempt under sections 610.021(3) and (13) of the Sunshine Law, which pertain to personnel records and information related to employee performance.The Supreme Court of Missouri reviewed the case and vacated the circuit court’s summary judgment. The court held that the record did not establish whether the DSNs were part of the requested vehicle stop data or if they were exempt from disclosure. The court emphasized that the Sunshine Law requires public records to be open unless specifically exempt and that the exemptions must be strictly construed. The case was remanded for further proceedings to determine whether the DSNs are public records and if any exemptions apply. View "Weeks vs. St. Louis County, MO." on Justia Law

In 1997, John Doe pleaded guilty to two class C felonies: deviate sexual assault in the first degree and sexual assault in the first degree. He was placed on probation for five years and registered as a sex offender under the Missouri Sex Offender Registry Act (MO-SORA). After completing probation in 2002, his criminal records were sealed. Despite this, Doe remained on the sex offender registry. Over the years, MO-SORA was amended to include more stringent requirements, such as public disclosure of registrants' information, in-person reporting, and lifetime registration for certain offenses.Doe filed a petition for declaratory and injunctive relief in the Circuit Court of St. Louis County, arguing that the amendments to MO-SORA violated his substantive due process rights and constituted an ex post facto law. The circuit court ruled against Doe on all claims, leading to his appeal.The Supreme Court of Missouri reviewed the case and affirmed the lower court's judgment. The court held that Doe has no fundamental right to privacy in the information required by the registry, as the information was already public before his records were sealed. The court found that MO-SORA is rationally related to the legitimate state interest of protecting children and public safety. Additionally, the court determined that MO-SORA is civil in nature and does not constitute a punitive ex post facto law. The court concluded that the registration requirements, including lifetime registration and in-person reporting, are not excessive and serve the non-punitive purpose of public safety. Therefore, the court upheld the constitutionality of MO-SORA's registration requirements. View "Doe v. Olson" on Justia Law

Marcellus Williams was convicted of first-degree murder and sentenced to death following a jury trial. His conviction and sentence were affirmed by the Supreme Court of Missouri, and his postconviction relief was denied. Williams sought additional DNA testing through a habeas corpus petition, which led to a temporary stay of execution and the appointment of a special master to oversee the testing. The results did not demonstrate his innocence, and his habeas petition was denied. Subsequent petitions for writs of habeas corpus and declaratory judgment were also denied.The St. Louis County prosecutor filed a motion to vacate Williams' conviction and death sentence, citing potential actual innocence based on DNA evidence, ineffective assistance of counsel, and racial discrimination in jury selection. This motion remains pending in the circuit court. Despite this, the Supreme Court of Missouri issued a warrant of execution for Williams, setting a new execution date.The Supreme Court of Missouri reviewed Williams' motion to withdraw the warrant of execution, arguing that the prosecutor's motion constituted a state postconviction motion, which should bar setting an execution date. The court found that Rule 30.30(c) only refers to postconviction motions filed by the defendant, not the prosecutor. Since Williams had already exhausted his state postconviction remedies, the court held that the execution date was properly set. The court also noted that the pending prosecutor's motion did not automatically warrant a stay of execution and that Williams had not demonstrated the necessary factors for equitable relief. Consequently, the court overruled Williams' motion to withdraw the warrant of execution. View "State v. Williams" on Justia Law

The case revolves around Benjamin Ramirez, who, on behalf of a putative class, sued the Director and the Treasurer of the Missouri Department of Revenue in their official capacities. Ramirez had resolved criminal charges against him by pleading guilty and paying court costs, including certain mandatory surcharges. These surcharges were then paid to various funds, as authorized by Missouri statute. Ramirez alleged that the Director and the Treasurer received payment of, collected, and deposited the surcharges in and otherwise managed these funds. He claimed a single count of unjust enrichment and asserted the statutes authorizing the surcharges violate a section of the Missouri Constitution.The Director and the Treasurer moved for summary judgment, asserting that Ramirez’s suit is barred by sovereign immunity and the statutes authorizing the surcharges do not violate the Missouri Constitution. The circuit court sustained the motion, concluding the statutes authorizing the surcharges do not violate the Missouri Constitution. Ramirez appealed this decision.The Supreme Court of Missouri affirmed the circuit court's judgment. The court held that sovereign immunity, a common law judicial doctrine barring suit against a government or public entity, applied to Ramirez's claim for unjust enrichment. The court noted that sovereign immunity is the default rule in all suits against the state and applies to non-tort claims. The court found that the state had not waived its sovereign immunity through express statutory consent or a recognized common law exception. Therefore, Ramirez's unjust enrichment suit against the Director and the Treasurer was barred by sovereign immunity. View "Ramirez vs. Missouri Prosecuting Attorneys' & Circuit Attorneys' Retirement System" on Justia Law

The case involves a group of appellants, collectively referred to as "Challengers", who appealed judgments declaring section 67.1175.1 of the Missouri Statutes constitutionally invalid. This provision, in conjunction with section 67.1177, required a political subdivision to grant public money to a private entity, which was deemed to violate article VI, section 23 of the Missouri Constitution. The circuit court attempted to rectify the constitutional invalidity by modifying section 67.1175.1. The Challengers, however, argued that despite the modification, the sections still required a political subdivision to grant public money to a private entity in violation of the constitution. They further argued that the entire statutory scheme must be struck down because the sections were not severable.The circuit court had declared section 67.1175.1 constitutionally invalid because it mandated the lake area business districts to transfer tax funds to the advisory board, a private nonprofit entity. The court modified the section by removing the phrase "which shall be a nonprofit entity". The Challengers appealed this decision, arguing that the modified sections still violated the constitution.The Supreme Court of Missouri found that the circuit court erred in modifying section 67.1175.1. The court concluded that the section, as modified, and section 67.1177, still required political subdivisions to grant public money to a private entity, violating the Missouri Constitution. The court also concluded that the void provisions were not severable from the remaining provisions of the statutory scheme. As a result, the entire statutory scheme was declared constitutionally invalid. The circuit court’s judgment was reversed, and the Supreme Court entered the judgment the circuit court should have entered, declaring sections 67.1170, 67.1175, 67.1177, and 67.1170 constitutionally invalid and void in their entireties. View "Salamun v. The Camden County Clerk" on Justia Law