Justia Missouri Supreme Court Opinion Summaries

Late at night, a police officer in Jefferson City observed a vehicle behaving suspiciously in a closed business area known for crime. The officer stopped the vehicle, which was driven by James Eggleston with a female passenger. The passenger appeared to be under the influence of narcotics, and Eggleston volunteered that he had an outstanding warrant and did not consent to a search of the vehicle. After arresting Eggleston, the officer contacted a canine unit. The canine alerted to the driver's side, leading officers to search the vehicle and find a bottle containing four baggies of methamphetamine within easy reach of the driver's seat. Additional drug paraphernalia and the passenger’s identification were found on the passenger side.The State charged Eggleston with possession of a controlled substance in violation of Missouri law. Following a bench trial in the Circuit Court of Cole County, the judge found Eggleston guilty and sentenced him to three years in prison. Eggleston appealed, arguing that the evidence was insufficient to prove he knowingly possessed the methamphetamine, particularly since it was in a shared compartment and could have belonged to the passenger.The Supreme Court of Missouri reviewed the case, applying the statutory definitions of “knowingly” and “possessed” and clarifying that joint possession does not require “additional incriminating evidence” beyond proximity and control. The court held that circumstantial evidence, including the methamphetamine’s location within Eggleston’s reach, his conduct, and other contextual facts, was sufficient for a rational factfinder to conclude he knowingly possessed the controlled substance. The Supreme Court of Missouri affirmed the circuit court’s judgment, holding that the conviction was supported by sufficient evidence and rejecting prior case law that imposed heightened burdens in joint possession cases. View "State of Missouri vs. Eggleston" on Justia Law

Amanda Rogers was convicted of unlawful possession of a firearm by a felon after an incident in which she drove a vehicle with a passenger, Seller, who attempted to sell a gun to Informant. Informant notified law enforcement after Seller, a known felon, tried to sell him a firearm and could not provide proof of ownership. Rogers drove Seller to meet Informant; after the attempted sale, Informant described the vehicle, its occupants, and its direction to law enforcement. Trooper Enderle located the vehicle, initiated a stop after backup arrived, and found Rogers acting suspiciously. A subsequent search revealed compatible ammunition on the driver’s side and a firearm within easy reach of both front seats. Rogers denied knowledge of a firearm and refused consent to search. After a canine unit arrived, law enforcement found the firearm in a bucket between the seats.The Circuit Court of Polk County, following a jury verdict of guilty, sentenced Rogers to seven years’ imprisonment and placed her in a long-term treatment program. Rogers moved to suppress the firearm and ammunition, arguing lack of probable cause for the stop and insufficient evidence of knowing possession. The circuit court denied both motions. She appealed, raising the same issues, and the Missouri Court of Appeals reviewed the case before the Supreme Court of Missouri granted transfer.The Supreme Court of Missouri held that the state presented sufficient evidence for a reasonable factfinder to conclude Rogers knowingly possessed the firearm, applying statutory definitions of possession and knowledge, and rejected the requirement for “additional incriminating evidence” in joint possession cases. The Court also found that Trooper Enderle had probable cause to search the vehicle, based on Informant’s tip, corroborating circumstances, and Rogers’ conduct. The judgment of the circuit court was affirmed. View "State of Missouri vs. Rogers" on Justia Law

The appellant brought a defamation action against two individuals, with whom he had prior romantic relationships. After those relationships ended, one defendant told others that the appellant had raped and abused her, while the other engaged in a broad social media campaign accusing the appellant of stalking, rape, threats, and violent behavior. These statements led to significant consequences for the appellant, including being confronted at his home by an armed group, being forced to leave his residence for months, being excluded from a local coffee shop, losing organizational affiliations and a speaking engagement, and being removed from shared office space.The case was first heard in the Circuit Court of St. Louis County. At the close of the appellant’s evidence, both defendants moved for directed verdicts, arguing that the appellant had failed to present evidence of reputational harm independent of his own testimony. The circuit court sustained the motions and entered judgment for the defendants, apparently on that sole ground. Four counts against one defendant related to agency were also dismissed; the appellant later abandoned those claims on appeal.The Supreme Court of Missouri reviewed the case. It held that a plaintiff in a defamation action is not required to provide independent evidence of reputational harm, and that credible testimony by the plaintiff may suffice if it establishes actual injury to reputation. The court found that the appellant’s testimony regarding the consequences of the defendants’ statements was sufficient for a reasonable jury to find reputational damage. The judgment in favor of the defendants was affirmed with respect to the abandoned agency-based counts, but was vacated as to all other counts. The case was remanded for a new trial on those remaining claims. View "Apperson v. Kaminsky" on Justia Law

Two homeowners purchased a lot in a subdivision that was subject to restrictive covenants, including one prohibiting the installation of solar panels on residences. After their purchase, Missouri’s legislature enacted a statute barring covenants or restrictions that limit or prohibit solar panel installations on rooftops. The homeowners attempted to work with their homeowners’ association to amend the restriction, but the association maintained the ban, later offering only limited permission for panels not visible from the street. The homeowners then sought declaratory and injunctive relief, challenging the enforceability of the covenant and the association’s rule on street-facing panels.The Circuit Court of Greene County denied relief to the homeowners, ruling that the new statute applied only to covenants created after its effective date and that applying it to preexisting covenants would impermissibly impair the contractual rights established before the statute’s enactment. The court found that retrospective application of the law was unconstitutional under Missouri’s constitution.On appeal, the Supreme Court of Missouri reviewed the judgment de novo. The Court held that the legislative intent and the statute’s language supported applicability to all covenants, including those enacted before the statute’s effective date. The Court determined that, while the statute operates prospectively, it renders prior prohibitions unenforceable from the effective date forward, without violating constitutional prohibitions against retrospective laws or impairing contracts. The Court found that the association’s rule prohibiting street-facing solar panels adversely affected cost and efficiency and could not be enforced under the statute.The Supreme Court of Missouri reversed the judgment of the Circuit Court, entered judgment for the homeowners, and held that both the covenant banning solar panels and the rule prohibiting street-facing panels were unenforceable under section 442.404.3. View "Eikmeier v. Granite Springs Home Owners Association, Inc." on Justia Law

After the Missouri General Assembly enacted Senate Bill No. 22 (SB 22) in 2025, which made several changes to statutes governing ballot summaries and judicial proceedings, a Missouri resident and taxpayer challenged its constitutionality. SB 22 as introduced focused solely on amending the process for judicial review of ballot summary statements. During the legislative process, SB 22 was amended to include provisions expanding the attorney general’s authority to appeal certain preliminary injunctions, a subject unrelated to ballot summaries, and the bill’s title was changed from “relating to ballot summaries” to “relating to judicial proceedings.” After passage by both legislative chambers and the Governor’s signature, the bill became law.The Circuit Court of Cole County reviewed the case after the plaintiff alleged SB 22 violated the Missouri Constitution’s original purpose, single subject, and clear title requirements, as well as equal protection guarantees. The circuit court found the bill did not violate the procedural constitutional provisions, but it did find that the amendment to section 526.010 (concerning the attorney general’s appellate rights) violated equal protection and was severable from the rest of the bill. The court allowed the remaining portions, primarily those addressing ballot summaries, to stand. The plaintiff appealed, challenging the findings on the procedural requirements, while the State cross-appealed on standing and equal protection.The Supreme Court of Missouri heard the case and held that the plaintiff had taxpayer standing because SB 22’s provisions resulted in a direct expenditure of public funds. Upon de novo review, the Supreme Court found that SB 22 violated the original purpose requirement of article III, section 21 of the Missouri Constitution because the added provision regarding the attorney general’s appellate rights was not germane to the bill’s original purpose. The Court further held that the offending provision could not be severed, and therefore invalidated SB 22 in its entirety, reversing the judgment of the circuit court. View "Nicholson v. State" on Justia Law

Craig M. Wood was convicted of abducting and murdering 10-year-old Hailey Owens in Springfield, Missouri. After eyewitnesses reported the abduction and provided Wood’s license plate number, police traced it to Wood's residence. Upon searching his home, officers found Hailey’s body in the basement, along with evidence of sexual assault and materials indicating Wood’s sexual interest in young girls. Wood was tried and found guilty of first-degree murder and sentenced to death.The Circuit Court of Greene County presided over Wood’s jury trial, entered judgment, and imposed the death sentence after the jury found multiple aggravating circumstances. The Supreme Court of Missouri previously affirmed Wood’s conviction and sentence on direct appeal in State v. Wood, 580 S.W.3d 566 (Mo. banc 2019). Wood then filed a Rule 29.15 motion for postconviction relief, arguing ineffective assistance of counsel on numerous grounds related to evidence, trial strategy, and mitigation. The motion court held an evidentiary hearing and denied the motion, finding no basis for relief.On appeal to the Supreme Court of Missouri, Wood raised 22 points concerning counsel’s performance and other alleged errors. The court reviewed whether the motion court’s findings and conclusions were clearly erroneous, applying the standard set forth in Rule 29.15(k). The Supreme Court of Missouri held that none of Wood’s claims demonstrated deficient performance or prejudice under the Strickland v. Washington standard. The court found the motion court’s factual determinations and legal conclusions were not clearly erroneous and affirmed the denial of postconviction relief. The judgment overruling Wood’s Rule 29.15 motion was affirmed. View "Wood vs. State of Missouri" on Justia Law

The Missouri General Assembly enacted two statutes effective August 28, 2023: the SAFE Act, which generally prohibits health care providers from performing gender transition surgeries or prescribing cross-sex hormones and puberty-blocking drugs for minors, and the Medicaid ban, which precludes MO HealthNet payments for such treatments when used for gender transition. The statutes include specific exemptions, such as for treatment of certain medical conditions and for minors already receiving such care prior to enactment. E.N., on behalf of her minor child and joined by medical professionals and organizations, challenged both laws, alleging violations of equal protection, due process, and the gains of industry clause under the Missouri Constitution.The Circuit Court of Cole County conducted a two-week bench trial and entered judgment in favor of the State, upholding the constitutionality of both statutes. The court found the challengers had raised only facial challenges and determined that neither statute violated the constitutional provisions cited. The challengers appealed, raising multiple points of error regarding the constitutional analysis and factual findings at trial.The Supreme Court of Missouri reviewed the circuit court’s determination de novo, applying a presumption of constitutionality. Relying on recent decisions from the United States Supreme Court and the United States Court of Appeals for the Eighth Circuit, the court held that both statutes classify based only on age and medical use, not on sex or transgender status. Thus, rational-basis review applied. The court found that the statutes are rationally related to legitimate state interests, such as safeguarding minors and managing public resources, and do not infringe fundamental rights. The court affirmed the circuit court’s judgment, concluding that the challengers failed to demonstrate any constitutional violation. View "E.N. v. Kehoe" on Justia Law

Richard James Johnson was charged with three moving violations in Missouri, including a class E felony charge for driving while intoxicated (DWI) as a persistent offender. The persistent offender charge was based on Johnson’s alleged prior DWI convictions on two separate occasions. Johnson argued that, under recent Supreme Court precedent, any fact that could increase the range of punishment—such as whether prior DWI convictions occurred on separate occasions—must be determined by a jury, not solely by a judge.The Circuit Court of Franklin County agreed with Johnson and dismissed the class E felony DWI charge, finding that the statute governing persistent offender status violated Johnson’s Fifth and Sixth Amendment rights by not requiring a jury determination of the “separate occasions” element. The State sought review from the Missouri Court of Appeals, which denied its writ petition. The State then sought relief from the Supreme Court of Missouri, which issued a preliminary writ of prohibition.The Supreme Court of Missouri reviewed whether section 577.023.2, which assigns the fact-finding responsibility for persistent offender status to the trial judge, is facially unconstitutional. The court held that the statute is not facially unconstitutional because it is possible for the jury to determine the relevant facts in accordance with constitutional requirements. The statute can be applied constitutionally if, after the judge’s initial finding, the jury also finds beyond a reasonable doubt that the defendant is a persistent offender. Therefore, the circuit court lacked authority to dismiss the felony charge on facial constitutional grounds. The Supreme Court of Missouri made permanent its preliminary writ of prohibition, ordering the circuit court to set aside its dismissal of the class E felony DWI charge. View "State ex rel. Catherine Hanaway vs. Hellmann" on Justia Law

Richard Neil Burkett was involved in a physical altercation with his brother-in-law at a convenience store in Texas County, Missouri. Witnesses stated that after being separated from his brother-in-law, Burkett pointed a semiautomatic handgun at him, threatened him, and pulled the trigger, although the gun did not fire. Burkett gave several inconsistent accounts to law enforcement, at first denying having a gun, then claiming self-defense, and finally admitting to pointing the gun after the fight was over. At trial, Burkett’s defense was that he never intended to harm his brother-in-law and only sought to scare him, arguing his gun was unloaded and he lacked intent to injure.The Circuit Court of Texas County conducted a jury trial, where Burkett was found guilty of first-degree assault and armed criminal action. During trial, Burkett did not request a self-defense instruction nor object to the jury instructions, and his counsel did not object to the State’s closing argument, which inaccurately stated that intent was not required for first-degree assault. Burkett’s post-trial motion did not raise these issues.The Supreme Court of Missouri reviewed Burkett’s appeal, in which he requested plain error review on two grounds: the lack of a self-defense instruction and the absence of a curative instruction after the State’s misstatement of law in closing argument. The court held that although Burkett may have injected self-defense into the case through his testimony, he failed to request the instruction or object to its absence, and his trial strategy was inconsistent with self-defense. Similarly, Burkett did not object to the State’s closing argument or request a curative instruction. The Supreme Court of Missouri exercised its discretion to decline plain error review for both claims and affirmed the judgment of the circuit court. View "State v. Burkett" on Justia Law

On February 4, 2020, Isis S. Jones engaged in a series of phone calls with D.W. while D.W. was at Victim’s apartment. After a heated argument, Victim drove D.W. to her aunt’s house, during which Jones continued calling. Near their destination, Victim heard a gunshot, stopped her car, and Jones approached the vehicle, hitting the driver’s side window with a gun. D.W. exited and fought with Jones, while Victim drove away, hearing a second gunshot. Police later observed a bullet hole in Victim’s vehicle, and Victim identified Jones as the shooter. Jones was charged with unlawful use of a weapon—specifically, the class B felony of shooting at a motor vehicle—and an accompanying charge of armed criminal action.The Circuit Court of the City of St. Louis conducted a jury trial, during which the jury was instructed to decide if Jones had shot “into” a motor vehicle, which corresponds to a class E felony, rather than “at” a motor vehicle as charged. Jones did not object to this instruction. The jury found Jones guilty of unlawful use of a weapon and armed criminal action. Jones subsequently entered into a sentencing agreement, receiving a 15-year sentence for the weapon charge (execution suspended for probation) and three years for armed criminal action. Jones appealed, arguing for the first time that the variance between the charged offense and the jury instruction led to manifest injustice due to the greater sentence imposed.The Supreme Court of Missouri reviewed Jones’ claim under Rule 30.20 for plain error, which allows discretionary review of unpreserved errors resulting in manifest injustice. The court held that Jones failed to establish substantial grounds that the circuit court committed plain error, as the distinction between shooting “at” and “into” a vehicle did not constitute a facially evident, obvious, and clear error. The court declined plain error review and affirmed the circuit court’s judgment. View "State v. Jones" on Justia Law