Justia Missouri Supreme Court Opinion Summaries

In 2019, MO CANN Do, Inc. (MCD) applied for a medical marijuana cultivation license in Missouri. However, the Department of Health and Senior Services (DHSS) rejected MCD's application as it failed to include a certificate of good standing demonstrating its authorization to operate as a business in Missouri. An administrative hearing commission upheld DHSS's decision, and MCD appealed to the circuit court, which also affirmed the decision.The Supreme Court of Missouri found that MCD's application did not meet the minimum standards for licensure, as it failed to provide a certificate of good standing from the Secretary of State, as required by DHSS's regulations. MCD argued that its certificate of incorporation satisfied the standard requiring proof of authorization to operate as a business in Missouri, but the Court disagreed, stating that the regulatory language was unambiguous and the certificate of good standing was a specific requirement.MCD further argued that DHSS waived the certificate of good standing requirement by failing to specify it in the deficiency letter sent to MCD. The Court rejected this argument, stating that DHSS never affirmatively waived the deficiencies in MCD's application.Lastly, MCD claimed that DHSS should be estopped from denying its application based on the missing certificate of good standing due to its failure to notify MCD of this specific deficiency. The Court denied this claim, stating that it is generally inappropriate to estop governmental agencies tasked with administrating licensure in highly regulated industries, which include the marijuana industry. In conclusion, the Supreme Court of Missouri affirmed the circuit court’s judgment. View "MO CANN Do, Inc. vs. Missouri Department of Health and Senior Services" on Justia Law

On December 13, 2023, the Supreme Court of Missouri issued an execution warrant for Brian Dorsey, who is serving a death sentence for two counts of first-degree murder. Subsequently, Dorsey filed two petitions for writ of habeas corpus, arguing that he is innocent as he was incapable of deliberation due to drug-induced psychosis at the time of the offenses, that his trial counsel was ineffective due to a conflict of interest resulting from a flat-fee arrangement, and that his execution would violate the Eighth Amendment as he belongs to a unique class of persons for whom the penological goals supporting capital punishment are no longer met.The Court found that Dorsey failed to present any legally cognizable claims for habeas relief. He did not deny committing the murders and failed to establish that he was actually innocent of first-degree murder. The Court had previously found Dorsey's claim of ineffective assistance of counsel due to a conflict of interest to be without merit, and he was procedurally barred from raising this claim again. Lastly, Dorsey's Eighth Amendment claim was deemed without merit and was interpreted as a plea for clemency, which is beyond the Court's review and authority. Therefore, both petitions for writ of habeas corpus were denied. View "State ex rel. Dorsey vs. Vandergriff" on Justia Law

The plaintiff, Yarnell, filed a wrongful death action against Clinton No. 1, Inc., a healthcare and rehabilitation center, alleging that Clinton's negligence led to her mother's death from COVID-19. The Missouri Supreme Court addressed whether Clinton's proposed theories of immunity barred Yarnell's claims, which were based on the Public Readiness and Emergency Preparedness (PREP) Act and two Missouri acts.Yarnell's mother had contracted with Clinton for a private room, but Clinton placed her with a roommate, which Yarnell claimed exposed her mother to COVID-19, violated their agreement, and ultimately led to her mother's death. Clinton argued that Yarnell's claims were barred by the PREP Act, which provides immunity for healthcare providers administering or using covered countermeasures during a public health emergency, and Missouri laws granting immunity to healthcare providers during an emergency declared by the governor and in COVID-19 exposure actions.The court found that Yarnell's petition did not implicate a covered countermeasure under the PREP Act, as it made no reference to the administration or use of a diagnostic test or any other covered countermeasure. The court also found that Clinton failed to demonstrate it agreed to be deployed during the emergency or that the governor or any state agency acted on such agreement and deployed Clinton, which would have entitled it to immunity under Missouri law. Lastly, the court noted that Yarnell had adequately alleged her harm was caused by Clinton's recklessness, and the two COVID-19 statutes would not foreclose relief if Yarnell were able to prove such recklessness. Therefore, the court quashed its preliminary writ of mandamus, allowing Yarnell's case to proceed. View "State ex rel. Clinton No. 1 vs. Baker" on Justia Law

Seven individuals sought a writ of mandamus or prohibition from the Supreme Court of Missouri, claiming the circuit court failed to hold a preliminary hearing within the required timeframe, thus violating Rule 22.09(a), section 544.270, and section 544.320. The plaintiffs argued that this delay was to allow the circuit attorney additional time to secure an indictment. The primary plaintiff, Lamar Lamont Woods, had been held without bond for 162 days on the complaint, with his preliminary hearing delayed for 129 days beyond the 30-day deadline in Rule 22.09(a).The Supreme Court of Missouri noted that after the filing of a felony complaint, a preliminary hearing should be held within a reasonable time, but no later than 30 days following the defendant's initial appearance if the defendant is in custody, and no later than 60 days if the defendant is not in custody. The Court concluded that Woods was not entitled to a preliminary hearing on his charges, as he had been indicted on the same charges at issue in the complaint filed in June 2023. Since Woods had been indicted, the Court ruled that any relief it might issue in mandamus would not have practical effect on any existing controversy, thus rendering the case moot.The Court also concluded that the "capable of repetition, yet evading review" exception to the mootness doctrine did not apply in this case, as Woods had not established this issue would recur. Consequently, the preliminary writ of mandamus was quashed. View "State ex rel. Woods vs. Dierker" on Justia Law

The Missouri Supreme Court ruled in a case involving the St. Louis County Assessor ("Assessor") and a group of St. Louis County commercial property owners, referred to as "Taxpayers." The Taxpayers alleged that their properties were assessed at a higher percentage of fair market value (FMV) than other commercial properties in the county. This claim is known as a "ratio discrimination" claim. The Taxpayers appealed their assessments to the local board of equalization ("BOE") and the Missouri State Tax Commission ("STC"). In some of the appeals, the BOE and STC did not change the Assessor's original FMV and assessed value, while in others, they ordered reductions in the estimated FMV of the property, resulting in a lower assessed value and decreased tax liability.The STC found that the Taxpayers did not provide substantial and persuasive evidence of discrimination. The Taxpayers then filed a petition for judicial review, and the circuit court reversed the STC's decision and order and remanded the case for retrial. The Assessor appealed to the Missouri Supreme Court, which found that the STC's decision was authorized by law and supported by substantial evidence. The Court agreed with the STC that the Taxpayers did not provide persuasive evidence of discriminatory assessment. The Court held that the actual assessment level used to analyze a claim of discriminatory assessment and taxation is based on the assessed value that actually determines the tax liability. The Court also found that the STC did not abuse its discretion by denying certain discovery requests and quashing subpoenas for the deposition of the Assessor and several staff appraisers. The circuit court's judgment was vacated, and the STC's decision and order was reinstated. View "Crown Diversified Industries Corp. v. Zimmerman" on Justia Law

In this case, the Supreme Court of Missouri affirmed a lower court's decision that a redistricting plan for the Missouri Senate, which was prepared by a judicial redistricting commission, met constitutional requirements. The appellants, residents of districts impacted by the redistricting, argued that the plan violated the community preservation requirement of the Missouri Constitution by splitting certain communities into different senatorial districts. The court found the appellants did not meet their burden of proving the plan was clearly and undoubtedly unconstitutional. The court noted that the constitution allows for some flexibility in the redistricting process and that the plan need not achieve absolute perfection. The court concluded that the redistricting plan did not violate the constitutional requirements and was not the result of partisan or racial gerrymandering. View "Faatz v. Ashcroft" on Justia Law

In Missouri, Planned Parenthood and other affiliated health organizations sought a declaratory judgment declaring House Bill No. 3014 (HB 3014) unconstitutional and requested injunctive relief to prevent its implementation and enforcement. HB 3014 was a bill passed by the Missouri General Assembly that would cut Medicaid funding for abortion providers and their affiliates, including Planned Parenthood. The plaintiffs alleged that the bill violated the single subject requirement and the equal protection clause of the Missouri Constitution. The Supreme Court of Missouri affirmed the decision of the lower court, which had ruled in favor of Planned Parenthood on both constitutional claims. The state appealed on procedural grounds, alleging that Planned Parenthood failed to exhaust administrative remedies, lacked standing, and waived its right to bring these claims. The state also argued the bill did not violate the single subject or equal protection provisions of the Missouri Constitution. However, the Supreme Court dismissed these arguments, affirming the lower court's ruling. View "Planned Parenthood of the St. Louis Region vs. Knodell" on Justia Law

On March 21, 2019, David Scott Nowicki was discovered unconscious in a vehicle in a ditch off Interstate 70 in Saline County, Missouri. After conducting field sobriety tests, Sergeant Dunfee concluded that Nowicki was impaired and arrested him. Nowicki was later transported to the Saline County jail, where he admitted he had been driving the vehicle but denied using alcohol or drugs in the last 72 hours. A jury trial was scheduled to determine whether Nowicki was guilty of driving while intoxicated. Before the trial, the circuit court was required to determine whether, if the jury found Nowicki guilty, he would be subject to an enhanced sentence due to prior convictions that qualified as intoxication-related traffic offenses (IRTOs). The state argued that Nowicki had four prior convictions that each qualified as an IRTO. As a result, the state contended Nowicki should be sentenced as a chronic offender. The jury found Nowicki guilty and the circuit court sentenced him as a chronic offender to five years in the department of corrections. Nowicki appealed the circuit court's judgment, arguing that the state failed to prove beyond a reasonable doubt that each of his four prior convictions qualifies as an IRTO.The Supreme Court of Missouri held that the state failed to prove beyond a reasonable doubt that each of Nowicki's prior convictions was an intoxication-related traffic offense. The court found that the state's evidence was insufficient to prove beyond a reasonable doubt that the conduct underlying Nowicki's 1986, 1990, and 1994 convictions involved him actually, physically driving a vehicle while intoxicated. Accordingly, the court vacated the circuit court's judgment and remanded the case for resentencing. View "State vs. Nowicki" on Justia Law

In 2012, Dane Templeton suffered an injury to his right knee and thigh after being thrown from a golf cart. Dr. Charles Orth operated on Templeton’s injured leg and provided follow-up care for several months. In 2015, Templeton returned to Dr. Orth due to swelling in his knee, prompting another surgery and more follow-up care that lasted until August 2016. However, Templeton decided to seek a second opinion from Dr. Michael Tilley in September 2016. After receiving an alternative treatment plan from Dr. Tilley, Templeton decided to follow this new plan and stopped taking the antibiotics prescribed by Dr. Orth. On October 9, 2018, Templeton filed a lawsuit against Dr. Orth for medical malpractice, alleging negligence in his treatment.Dr. Orth sought summary judgment, arguing that the lawsuit was barred by the two-year statute of limitations. According to Dr. Orth, Templeton ended the physician-patient relationship when he sought treatment from Dr. Tilley without following up with Dr. Orth. The circuit court agreed with Dr. Orth, concluding that the lawsuit was indeed barred by the statute of limitations. Templeton appealed this decision, arguing that the continuing care doctrine should have tolled the statute of limitations.The Supreme Court of Missouri affirmed the circuit court's judgment. The Supreme Court determined that Templeton had actively ended the continuing care relationship with Dr. Orth when he chose to follow Dr. Tilley's treatment plan and stopped taking the antibiotics prescribed by Dr. Orth. As such, Templeton's lawsuit, filed more than two years after ending the physician-patient relationship, was barred by the statute of limitations. The Court clarified that the continuing care doctrine did not apply because the relationship had ended before the necessity for treatment had ceased. View "Templeton vs. Orth" on Justia Law

The Supreme Court of Missouri reversed a lower court's dismissal of a lawsuit brought by workers against Harley-Davidson Motor Company Operations, Inc., and Syncreon.US. The workers, who are Black or People of Color, alleged that the companies created a hostile work environment and aided and abetted racial discrimination in violation of the Missouri Human Rights Act. The workers detailed numerous racially charged incidents at a manufacturing and assembly facility operated by Harley-Davidson and staffed by workers provided by Syncreon.US. The incidents included frequent racial insults, physical division of workers based on race, and multiple instances of hate symbols and threats found in the facility. The court found that the workers' allegations, if true, could establish the elements of a hostile work environment claim and aiding and abetting claims. The case was remanded back to the lower court for further proceedings. View "Matthews vs. Harley Davidson" on Justia Law