Justia Missouri Supreme Court Opinion Summaries

After a bench trial, the appellant was convicted of first-degree murder and armed criminal action for the death of her husband. She was sentenced to life without parole and 30 years to be served concurrently. While her direct appeal was still pending, she filed a pro se motion under Missouri Supreme Court Rule 29.15 to set aside her conviction. The circuit court later appointed counsel for her postconviction proceeding. After the Missouri Court of Appeals affirmed her conviction and issued its mandate, appointed counsel entered an appearance but did not file an amended motion until after the deadline established by Rule 29.15.The Circuit Court of Douglas County found both the pro se and amended motions were untimely but determined appointed counsel had abandoned the appellant by failing to timely file the amended motion. The court proceeded to deny relief on the merits of the ineffective assistance of counsel claims asserted in the amended motion, including failure to call an expert on psychological shock and failure to request a competency evaluation, without holding an evidentiary hearing.The Supreme Court of Missouri reviewed the appeal. It held that the pro se motion was timely under the applicable version of Rule 29.15, as it was deemed filed immediately after the appellate mandate. However, the amended motion was untimely. The Court concluded the motion court properly found abandonment by appointed counsel, as the tardiness was solely counsel’s fault and supported by the record. In such cases, the amended motion should be treated as timely and the court may review its merits without remand for an abandonment hearing.On the merits, the Supreme Court of Missouri held the motion court did not clearly err in denying both ineffective assistance claims without an evidentiary hearing because the record refuted any showing of prejudice or need for further factual development. The judgment denying postconviction relief was affirmed. View "Young vs. State" on Justia Law

The case concerns an incident in July 2021 involving John Otis, a victim, and a minor child. Otis became angry while riding in a vehicle, leading to a series of violent acts. After initially driving away, Otis returned and struck the victim twice with the car, pinning her against a gas station building. He then assaulted her with a metal pole, punched her, and stomped on her until she lost consciousness. The child was present throughout the events and remained with the victim until help arrived. The victim suffered severe injuries and was hospitalized.The State charged Otis with three counts of first-degree domestic assault, armed criminal action, and endangering the welfare of a child. The Circuit Court of St. Charles County found Otis to be a persistent offender based on prior felony convictions in Missouri and Illinois, and sentenced him to life in prison for each domestic assault count, 15 years for armed criminal action, and seven years for endangering the welfare of a child. The sentences were ordered to run consecutively. A jury found Otis guilty of all charges. Otis appealed, challenging the persistent offender determination, the sufficiency of evidence supporting that finding, and the jury instructions.The Supreme Court of Missouri reviewed Otis’s appeal. The Court held that although recent U.S. Supreme Court precedent in Erlinger v. United States requires a jury, not a judge, to decide facts that increase penalty ranges, Otis’s claim was not preserved and did not warrant plain error review because he failed to demonstrate manifest injustice. The Court found sufficient evidence supported Otis’s persistent offender status, particularly regarding the Illinois felony conviction. It also declined to review the jury instruction claim for plain error. The Supreme Court of Missouri affirmed the circuit court’s judgment. View "State vs. Otis" on Justia Law

The case concerns an incident in which the defendant, alongside two accomplices, confronted a victim outside his home, robbed him at gunpoint, and shot him multiple times. The victim survived after extensive medical treatment and identified the defendant in a police lineup. The defendant was charged with several offenses, including first-degree robbery, first-degree assault, armed criminal action, second-degree burglary, and stealing. At trial, the court granted the defendant’s motion for acquittal on the burglary and stealing charges, and the jury found him guilty on the remaining four counts.Following the jury verdict, the Circuit Court of the City of St. Louis held a sentencing hearing. During this proceeding, the court referenced the defendant’s prior involvement in an unrelated carjacking case, in which the defendant had been acquitted of all charges that were not dismissed. Defense counsel did not object to these remarks. The court ultimately sentenced the defendant to consecutive prison terms totaling fifty years. The defendant appealed, arguing that the circuit court committed plain error by considering conduct from the acquitted charges without proof by a preponderance of the evidence.The Supreme Court of Missouri reviewed the defendant’s claim under the plain error standard because it was not preserved by objection at sentencing. The court held that the circuit court did not commit plain error in referencing the defendant’s prior acquittals, finding that the judge’s remarks were insufficient to show the sentence was based on unproven conduct. The court distinguished prior case law limiting the consideration of acquitted conduct to jury sentencing and found no manifest injustice. The Supreme Court of Missouri affirmed the circuit court’s judgment. View "State vs. Harris" on Justia Law

Michael Holmes was convicted in 2006 of federal drug charges based on testimony from two St. Louis City police officers. After internal investigations revealed repeated misconduct by the officers, Holmes’ conviction was vacated in 2011 and the charges were dismissed, leading to his release after five years in prison. Holmes then sued the officers and the Board of Police Commissioners in federal court for civil rights violations and state torts. The federal district court dismissed the state tort claims against the board on sovereign immunity grounds and granted summary judgment to the board on the section 1983 claims, but the claims against the officers went to trial. A federal jury found the officers liable under section 1983 and awarded Holmes $2.5 million.Following this judgment, Holmes sought a declaration in the Circuit Court of the City of St. Louis that either the State of Missouri or the City of St. Louis was obligated to indemnify the officers and pay the judgment. The circuit court initially ruled the State was responsible for payment from the state legal expense fund. On appeal, the Supreme Court of Missouri held that the State was not obligated to pay under the applicable statute and remanded the case for a determination of the City’s liability.On remand, Holmes and the City filed cross-motions for summary judgment. The circuit court granted summary judgment to the City, finding Holmes had not established the City’s liability. Upon further appeal, the Supreme Court of Missouri reviewed the case de novo and held that Holmes failed to demonstrate that the City waived its sovereign immunity through express statutory consent or a recognized common law exception. As a result, the Supreme Court of Missouri affirmed the circuit court’s judgment in favor of the City, holding the City is not obligated to indemnify the officers for the federal judgment. View "Holmes vs. Zellers" on Justia Law

A resident of St. Louis brought a class action lawsuit against the city, seeking a refund of fees paid for solid waste services. The plaintiff alleged that these fees were collected under the mistaken belief that the city was providing separate recycling and yard waste collection, which the city either failed to provide or did not provide consistently. The city had implemented a monthly solid waste services fee in 2010, increased it in 2017, and included the fee in residents’ water bills. Although the city at times collected recyclables and yard waste separately, it often did not, and ultimately terminated the program in 2025. The plaintiff argued that the city unjustly retained fees for services it did not render, seeking damages for herself and other residents.The Circuit Court of the City of St. Louis denied the city’s motion to dismiss, finding that the plaintiff’s claim for “money had and received” could proceed. The city then sought a writ of prohibition from the Missouri Court of Appeals, which was denied. The city subsequently sought relief from the Supreme Court of Missouri.The Supreme Court of Missouri held that the city is protected by sovereign immunity and that section 432.070 of the Missouri Revised Statutes bars the claim. The court found that the plaintiff’s allegations did not plead facts that would establish an exception to sovereign immunity for her claim and that no statutory or recognized common law exception applied. The court also concluded that the proprietary function exception did not apply, as solid waste collection is a governmental function. The court made its preliminary writ of prohibition permanent, directing that the plaintiff’s claim be dismissed. View "State ex rel. City of St. Louis vs. Whyte" on Justia Law

A group of individuals who had filed claims with the Missouri Division of Workers’ Compensation for compensation from the tort victims’ compensation fund during the 2022 claims period alleged that the division failed to pay the full amount of compensation stipulated by statute. The division determined that each claimant was entitled to an award, but the payments were prorated at 40 percent of their respective full values due to the amount appropriated by the Missouri General Assembly being less than the total value of awards. The claimants contended the division should have based the proration on the total amount of money in the fund, not just on the appropriated amount, which would have resulted in a higher payout percentage.The claimants initiated lawsuits against the division, the Missouri Department of Labor and Industrial Relations, the Labor and Industrial Relations Commission, and associated officials, seeking declaratory and injunctive relief. After a bench trial, the Circuit Court of Cole County found in favor of the defendants, holding that the lawsuits were barred by sovereign immunity and that the claimants had failed to exhaust their administrative remedies. The circuit court also ruled, in the alternative, that the defendants’ interpretation of the relevant statute prevailed.Upon appeal, the Supreme Court of Missouri reviewed the case and affirmed the circuit court’s judgment. The Supreme Court held that the “sue and be sued” language in the enabling statutes for the division and commission did not constitute a waiver of sovereign immunity for this type of claim. The statutes governing the fund did not permit the claimants’ action, as the legislature explicitly barred claims against the state for unpaid or underpaid awards due to lack of appropriations. Additionally, the court found that claimants failed to exhaust the specific administrative review process provided by statute, which is the exclusive method for challenging such decisions. View "Jones vs. Missouri Labor and Industrial Relations Commission" on Justia Law

In August 2025, the governor of Missouri issued a proclamation calling for an extraordinary legislative session. The session was convened to address two issues: establishing new congressional districts and changing the initiative petition process. The governor explained that the legislature had adjourned without enacting new district boundaries, which could expose the state to legal challenges, and that changes to the initiative petition process were needed to address concerns about foreign influence and voter confusion. During this extraordinary session, the legislature passed a new congressional map and proposed a constitutional amendment related to initiative petitions.On the day the session was to begin, the NAACP and two individuals filed suit in the Circuit Court of Cole County, seeking a declaration that the governor’s proclamation did not state an “extraordinary occasion” as required by article IV, section 9 of the Missouri Constitution. They also sought to enjoin the session and later the implementation of the enacted measures. The circuit court, after a bench trial, ruled in favor of the state officials, finding that the governor had constitutional authority to call the extraordinary session and that the question was a political one, best decided by the governor.The Supreme Court of Missouri, reviewing the circuit court’s declaratory judgment, affirmed the decision. The court held that article IV, section 9 vests the governor with discretion to determine when an extraordinary occasion has arisen and to call an extraordinary session accordingly. The court rejected the argument that the governor’s discretion is limited by an objective definition of “extraordinary,” finding that neither the constitutional text nor its historical context imposed such a restriction. The judgment of the Circuit Court of Cole County was affirmed. View "National Association for the Advancement of Colored People Missouri State Conference vs. Kehoe" on Justia Law

James Guthrie was charged with multiple counts of sexual offenses involving two victims. Relevant to this appeal, one count alleged that Guthrie committed first-degree statutory rape against Victim 2, specifically that he knowingly had sexual intercourse with her when she was less than fourteen years old. At trial, Victim 2 testified that the incident occurred in 2017, and though she initially indicated it happened when she was 14, she also described herself as a “preteen” at the time. The defense argued that the evidence was insufficient to prove the offense took place before Victim 2 turned fourteen.After a jury trial in the Circuit Court of Mississippi County, Guthrie was found guilty on all counts. He appealed, contending that the evidence did not establish beyond a reasonable doubt that Victim 2 was under fourteen when the offense occurred. The Missouri Court of Appeals initially reviewed the case, and then the Supreme Court of Missouri accepted transfer and exercised jurisdiction.The Supreme Court of Missouri held that, under the standard requiring the court to view evidence and reasonable inferences in the light most favorable to the verdict, the jury was permitted to credit Victim 2’s testimony that she was a “preteen” at the time of the incident, which by definition means younger than thirteen. The Court found that this testimony provided sufficient evidence that the crime occurred before Victim 2 turned fourteen, as required by statute. The Court rejected arguments that conflicting testimony or the lack of precise dates undermined the verdict, and it noted that no due process or instructional challenges were preserved. Accordingly, the Supreme Court of Missouri affirmed the conviction and the judgment of the circuit court. View "State vs. Guthrie" on Justia Law

After the Missouri legislature enacted a new congressional redistricting map in 2025, two groups of residents challenged its constitutionality. The residents argued that the map violated article III, section 45 of the Missouri Constitution, which requires congressional districts to be comprised of contiguous territory, to be as compact as possible, and to have nearly equal populations. Their claims focused particularly on districts 4, 5, and 6, alleging lack of compactness, improper splitting of Kansas City communities, and that a voting tabulation district (KC 811) was assigned to two congressional districts, violating contiguity and equal population requirements.The Circuit Court of Jackson County consolidated the two cases and held a bench trial. After reviewing extensive expert and lay testimony, statistical measures of compactness, and evidence regarding county and municipal splits, the circuit court found that the 2025 Map was more compact than prior maps, satisfied contiguity and equal population requirements, and did not violate the constitutional standards. The circuit court rejected claims regarding community splits and alternative maps, emphasizing its role was not to weigh policy preferences but to apply constitutional directives.On appeal, the Supreme Court of Missouri reviewed the circuit court’s factual findings with deference and applied de novo review to legal questions. The Court held that the plaintiffs failed to demonstrate the 2025 Map clearly and undoubtedly violated article III, section 45. The Court emphasized that statistical and historical comparisons supported the circuit court’s findings, and that departures from compactness, if any, were minimal and justified by recognized factors. The Supreme Court of Missouri affirmed the circuit court’s judgment, upholding the constitutionality of the 2025 Map. View "Healey vs. State" on Justia Law

In September 2025, the Missouri General Assembly enacted HB 1, which redrew congressional districts despite no new census certification. Two Missouri voters, affected by the redistricting, signed and helped submit a referendum petition to challenge HB 1 before it took effect in December 2025. They argued that upon filing the petition with the secretary of state on December 9, 2025, HB 1 was automatically suspended under the Missouri Constitution until voters could decide on it. They also contended that any statutes allowing the secretary to delay suspension until official verification conflicted with constitutional provisions.The Circuit Court of Cole County held a bench trial on stipulated facts. It dismissed the voters’ petition on several grounds—lack of standing, lack of ripeness, the political question doctrine, and the existence of an adequate statutory remedy. On the merits, it also declared that filing the referendum petition did not automatically suspend HB 1. The voters appealed, and the Supreme Court of Missouri accepted transfer to review the important legal question presented.The Supreme Court of Missouri held that simply filing a referendum petition does not automatically suspend a legislative act under article III, sections 49, 52(a), or 52(b) of the Missouri Constitution. The Court reasoned that such suspension only occurs if the referendum petition is ultimately determined to be legal, sufficient, and timely, as required by constitutional and statutory provisions. The ongoing statutory process for verifying signatures and certification by the secretary of state must be completed to determine sufficiency. The Court also rejected the argument that the relevant statutes were unconstitutional as applied. The judgment of the circuit court was affirmed. View "Maggard vs. State" on Justia Law