Justia Missouri Supreme Court Opinion Summaries

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

Jeromy McCrackin filed a wrongful death action against Tynan Mullen for the death of McCrackin’s son, who was shot and killed outside a pool hall in 2019. Safeco Insurance Company of America had issued a homeowners insurance policy to Mullen’s grandmother, with whom Mullen allegedly lived at the time. Mullen was indicted for first-degree murder and armed criminal action but pleaded guilty to first-degree involuntary manslaughter and armed criminal action. McCrackin offered to settle the wrongful death claim against Mullen in exchange for Safeco’s agreement to pay the total liability coverage limits, which Safeco declined, stating the policy excluded coverage for intentional acts.The Circuit Court of Jackson County overruled Safeco’s motion to intervene in the wrongful death action for the purpose of seeking a stay until a separate federal declaratory judgment action could be resolved. Safeco had filed the federal action to determine whether it had a duty to defend or indemnify Mullen. The circuit court held a bench trial in the wrongful death action, overruled Safeco’s motion to intervene, and entered a judgment against Mullen, awarding McCrackin $16.5 million in damages.The Supreme Court of Missouri reviewed the case and held that Safeco had a right to intervene in the wrongful death action pursuant to Rule 52.12(a)(2) for the limited purpose of seeking a stay. The court found that Safeco had an interest in the wrongful death action and that the disposition of the action could impair or impede its ability to protect that interest. The court vacated the circuit court’s judgment and remanded the case for further proceedings consistent with its opinion. The court did not direct how the circuit court should rule on the motion to stay, leaving that decision to the lower court. View "McCrackin vs. Mullen" on Justia Law

Joe David Hudson was injured while working for Joplin Regional Stockyards, Inc. (JRS) in 2002. In 2005, Hudson, JRS, and JRS' insurer, Star Insurance Company, entered into a settlement agreement where Hudson received an $80,000 lump sum. The settlement left future medical expenses for Hudson's left ankle open. In 2011, Hudson had a below-the-knee amputation, which Star refused to cover. Hudson filed the settlement in circuit court in 2013, and the court rendered judgment in accordance with the settlement. Hudson later filed an equitable garnishment action, leading Star to pay $92,000 for his medical bills. In 2015, Star agreed to reimburse Hudson up to $610,311.75 for future medical expenses. In 2016, Hudson and JRS entered into a subordination agreement, acknowledging all payments due under the judgment had been received.In 2022, Hudson filed a motion to revive the judgment, which JRS opposed, arguing the judgment had been satisfied and the Division of Workers' Compensation had not determined the future medical care provision. JRS also filed a motion for relief from the judgment, claiming it was void due to lack of due process. The Circuit Court of Jasper County sustained Hudson's motion to revive the judgment and overruled JRS' motion for relief.The Supreme Court of Missouri reviewed the case and determined that JRS had standing to appeal. The court found that the circuit court erred in reviving the judgment because JRS had satisfied the judgment by paying the $80,000 lump sum. The court reversed the circuit court's order sustaining Hudson's motion to revive the judgment and overruled Hudson's motion to revive the judgment. Hudson's motion for damages for a frivolous appeal was also overruled. View "Hudson v. Joplin Regional Stockyards, Inc." on Justia Law

A tract of land was platted into a subdivision for single-family residential use, with restrictions recorded by the original owner. A subsequent purchaser, Ananda LLC, acquired the subdivision and attempted to develop it contrary to the restrictions. When these plans failed, Ananda transferred some lots to Nithyananda Dhyanapeetam of St. Louis and the remaining lots to Fogarty Farms LLC, which also received an assignment of developer rights. The case centers on whether developer rights were transferred and if the subdivision's restrictions were abandoned.The Circuit Court of Jefferson County found that developer rights were transferred from the original owner to Ananda and then to Fogarty Farms. The court held that the restrictions were not abandoned and that the property owners association created under the restrictions was valid. The court also invalidated a transfer of common ground and awarded attorney fees to the property owners association.The Supreme Court of Missouri reviewed the case and affirmed the circuit court's judgment. The court held that the totality of circumstances demonstrated the intent to transfer developer rights from Essex to Ananda and then to Fogarty Farms. The court also found that the restrictions were not abandoned, as there were no widespread violations indicating an intent to abandon the plan. The court upheld the circuit court's decision that the lake lot remained common ground, as removing it would be unjust given Nithyananda's reliance on its status. Finally, the court affirmed the award of attorney fees to the property owners association, finding no abuse of discretion in the amount awarded. View "Millstone Property Owners Association vs. Dhyanapeetam" on Justia Law

Yolanda Bell obtained an automobile insurance policy from Shelter General Insurance Company. In February 2018, her vehicle was damaged, and Shelter determined it was a total loss, paying her $11,787 after deductions. Bell filed a class action suit in February 2022, alleging that Shelter breached its contractual duties by not including taxes and fees required to acquire a replacement vehicle in its payment. Bell argued that the policy did not require her to replace the vehicle before being reimbursed for these costs.The Circuit Court of Jackson County dismissed Bell's petition without prejudice, agreeing with Shelter's argument that the policy only covered taxes and fees if they were actually incurred by purchasing a replacement vehicle. Bell appealed the decision, standing on her original petition rather than amending it.The Supreme Court of Missouri reviewed the case de novo. The court found that Bell's petition adequately pleaded a breach of contract claim by alleging the existence of the insurance policy, her performance under the policy, Shelter's failure to pay the required taxes and fees, and the resulting damages. The court emphasized that the interpretation of the policy's terms was a matter for summary judgment or trial, not for a motion to dismiss. Consequently, the Supreme Court of Missouri reversed the circuit court's judgment and remanded the case for further proceedings. View "Bell vs. Shelter General Insurance Company" on Justia Law

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