Justia Missouri Supreme Court Opinion Summaries

A dispute arose over the 2016 property tax assessment for a hotel located at Kansas City International Airport. Grady Hotel Investments, LLC purchased the hotel improvements but not the land, which remained owned by the City of Kansas City. As the City is exempt from property taxes, Grady was taxed only on its possessory interest in the hotel improvements. The Platte County assessor valued the property at over $11 million, which was raised to more than $13 million by the Platte County Board of Equalization. On appeal, a State Tax Commission (STC) hearing officer reduced the value, and the full STC ultimately valued it at $0, using a method applicable to leaseholds. The assessor challenged this, and the circuit court found the STC’s valuation method inapplicable, determining Grady owned the improvements rather than holding a leasehold.The Missouri Court of Appeals affirmed the circuit court’s conclusion that Grady held an ownership interest, not a mere leasehold, and remanded the case for a new valuation. On remand, the STC valued the property at over $6 million. The assessor and Park Hill School District appealed, raising constitutional challenges to the valuation statute, section 137.115.1, arguing it violated provisions of the Missouri Constitution related to due process, tax exemptions, uniformity, and special privileges.The Supreme Court of Missouri reviewed the case. It held that Park Hill School District lacked standing to challenge the assessment, as its interest in potential funding loss did not confer standing to contest another’s property valuation. The assessor also lacked standing to assert claims under due process and special privilege provisions because, as a political actor, he was not protected by those constitutional rights. However, the assessor did have standing to challenge the statute under the tax exemption and uniformity provisions. The court held that section 137.115.1 neither creates an unconstitutional tax exemption nor violates the uniformity clause. The circuit court’s judgment was affirmed. View "Cox vs. Grady Hotel Investments, LLC" on Justia Law

After his employment as a wet plant foreman was terminated in January 2022, the plaintiff sent a certified letter in April 2022 to his former employer, requesting a service letter as required by Missouri law. He did not receive a response. The plaintiff later filed suit against the company, alleging a violation of section 290.140 for failure to provide the service letter. He also initially included a claim for disability discrimination under the Americans with Disabilities Act, but that claim was dismissed in federal court, and the remaining statutory claim was remanded to state court.The Circuit Court of Cape Girardeau County granted summary judgment to the defendant company. The defendant had argued that the plaintiff’s service letter request and lawsuit were directed at the wrong corporate entity, asserting that another related company had actually employed the plaintiff. The plaintiff failed to properly respond to the summary judgment motion as required by Rule 74.04(c)(2), instead making bulk admissions and denials without specific references to the record. Because of this failure, the court deemed the defendant’s factual statements admitted and found no genuine issue of material fact. The plaintiff appealed, and the Supreme Court of Missouri granted transfer after an opinion by the court of appeals.The Supreme Court of Missouri held that summary judgment is not an “extreme or drastic remedy” and reaffirmed the requirements for summary judgment motions and responses under Missouri law. The Court concluded that, because the plaintiff did not properly preserve or raise any arguments demonstrating error by the circuit court, and failed to comply with procedural rules, there was no basis to overturn the grant of summary judgment. The judgment of the circuit court in favor of the defendant was affirmed. View "Wilkinson vs. Farmers Holding Companies" on Justia Law

Several individuals and two organizations challenged a Missouri law enacted in 2022, House Bill No. 1878 (HB 1878), which amended the state’s voting requirements by mandating that voters present specific forms of photo identification or cast a provisional ballot under certain conditions. The organizations—the Missouri State Conference of the NAACP and the League of Women Voters of Missouri—along with the individuals, claimed that these provisions unconstitutionally burdened the right to vote and violated equal protection guarantees.Their petition for declaratory and injunctive relief was filed in the Circuit Court of Cole County. After a bench trial, the circuit court found that none of the individual plaintiffs had shown an actual or threatened injury, as each had either successfully voted since the law’s enactment or their alleged difficulties were speculative. The court also determined that the organizations had not established standing, either through a diversion of resources or by identifying any specific member adversely affected by the law. Despite these findings, the circuit court proceeded to rule on the merits, concluding the law was constitutional.The Supreme Court of Missouri, which has exclusive jurisdiction in cases involving the validity of state statutes, reviewed the matter. The Supreme Court affirmed the circuit court’s determination that the appellants lacked standing—meaning none of the plaintiffs demonstrated a concrete, personal stake in the outcome. The Supreme Court held that, because there was no justiciable controversy before the court, the circuit court erred by reaching and deciding the merits of the constitutional claims. Therefore, the Supreme Court reversed that portion of the judgment addressing the merits of the constitutional challenge. The case was thus resolved solely on the issue of standing. View "Missouri State Conference of the National Association for the Advancement of Colored People vs. State" on Justia Law

In 2022, Missouri enacted new legislation that imposed several restrictions on activities related to voter registration and absentee ballot applications. The law prohibited the payment or compensation of individuals for soliciting voter registration applications unless they were government employees, required anyone who solicited more than ten voter registration applications to register with the state, and mandated that solicitors be at least eighteen years old and registered Missouri voters. Additionally, the law completely banned the solicitation of voters to obtain absentee ballot applications. These provisions affected organizations whose work involves encouraging and assisting individuals in registering to vote and informing them about absentee voting.The Circuit Court of Cole County reviewed a lawsuit brought by two civic organizations challenging these provisions as unconstitutional. The organizations argued the restrictions violated rights to free speech, association, and due process under the Missouri Constitution. The court issued a preliminary injunction, and after trial, permanently enjoined enforcement of the provisions, finding them to be facially unconstitutional restrictions on core political speech, overbroad, content- and viewpoint-based, and unconstitutionally vague. The court concluded the state had not shown the provisions were narrowly tailored to serve a compelling governmental interest.On direct appeal, the Supreme Court of Missouri affirmed the circuit court’s judgment. The Supreme Court of Missouri held that the statutory provisions imposed facially unconstitutional restrictions on core political speech protected by article I, section 8 of the Missouri Constitution. The Court found the provisions neither served a compelling state interest nor were narrowly tailored, and instead captured substantial amounts of protected speech unrelated to any compelling interest. The judgment declaring the provisions unconstitutional was affirmed. View "State vs. League of Women Voters" on Justia Law

After the results of the 2020 United States census were certified to the governor of Missouri in August 2021, the Missouri General Assembly established new congressional districts in 2022, as required by the state constitution. In September 2025, the General Assembly passed House Bill 1 (“HB 1”), which repealed the 2022 congressional districts and established new ones, even though no new census had been certified. The governor signed HB 1 into law. A group of plaintiffs challenged the constitutionality of HB 1, arguing that article III, section 45 of the Missouri Constitution restricts the General Assembly to one redistricting following each decennial census certification.The Circuit Court of Cole County heard the case on stipulated facts and rejected the plaintiffs’ claim, finding that HB 1 was a valid exercise of the General Assembly’s legislative authority. The circuit court declared that article III, section 45 does not prevent the General Assembly from redistricting more frequently than once per decade.On appeal, the Supreme Court of Missouri reviewed the constitutional question de novo. The Court held that article III, section 45 obligates the General Assembly to redistrict upon certification of the decennial census but does not expressly prohibit mid-decade or more frequent congressional redistricting. The Court explained that, absent express constitutional restraint, the General Assembly’s legislative power remains plenary. The Court also found that the word “when” in section 45 acts as a trigger for mandatory redistricting but does not serve as a limitation on the legislature’s authority to redistrict at other times.The Supreme Court of Missouri affirmed the circuit court’s judgment, upholding HB 1 as constitutional and concluding that article III, section 45 does not restrict the General Assembly’s power to conduct mid-decade congressional redistricting. View "Luther vs. Hoskins" on Justia Law

The case involves an injury sustained by an individual while operating a forklift designed, manufactured, and distributed by a company. The injured party alleged that the forklift’s open operator compartment constituted a defective design, making the product unreasonably dangerous, and asserted that adding features such as a door or bumper would have prevented the accident. To support these claims, the injured party retained an expert witness to testify about the alleged defect and alternative, safer designs.In the Circuit Court of Jackson County, the defendant company filed motions both to exclude the plaintiff’s expert witness and for summary judgment. The court found that the expert’s testimony lacked reliability, as the plaintiff failed to demonstrate that the expert’s opinions were based on reliable principles and methods, or that those methods had been properly applied to the facts. The court noted the absence of relevant testing, peer-reviewed support, or clear connection between the expert’s analysis and the incident. Consequently, the court excluded the expert’s testimony. Without admissible expert evidence to support the defective design claim, the circuit court then granted summary judgment for the company, as there was no genuine issue of material fact.On appeal, the Supreme Court of Missouri reviewed only the grant of summary judgment. The court held that the circuit court did not abuse its discretion in excluding the expert’s testimony under section 490.065, as the plaintiff failed to establish the reliability of the expert’s methods or their application to the case. The Supreme Court of Missouri affirmed the circuit court’s judgment, holding that without admissible expert testimony, summary judgment was proper, including as to the punitive damages claim, because the plaintiff could not prevail on the underlying product liability claim. View "Hanshaw v. Crown Equipment Corp." on Justia Law

Two women, who were never married, were granted joint guardianship of twin girls when the children were very young. After their relationship ended, they continued to share custody through the guardianship. Several years later, both women filed competing adoption petitions. The circuit court granted one woman’s petition, making her the adoptive parent and terminating the guardianship. The other woman’s appeal of the adoption was unsuccessful.While that appeal was pending, the non-adoptive woman filed a petition in the Circuit Court of Jackson County seeking third-party custody or, alternatively, visitation rights under section 452.375.5(5). The adoptive parent moved to dismiss the petition, arguing her former partner lacked standing under the statute. The circuit court denied the motion, and the parties later appeared to reach a settlement, resulting in a proposed judgment granting third-party visitation. The adoptive parent objected before the judgment was entered, but the court signed the judgment granting visitation. When the adoptive parent was found to have violated this judgment, the court awarded compensatory visitation and attorney’s fees to the other woman. The adoptive parent appealed both rulings. The Missouri Court of Appeals affirmed, concluding the non-adoptive woman had standing and that consent to the visitation agreement was binding.The Supreme Court of Missouri reviewed the case and held that section 452.375.5(5)(a) does not create an independent cause of action for third-party custody or visitation when custody is not otherwise at issue in an underlying proceeding. The Court determined that a third party may only seek custody or visitation under the statute as part of an already pending custody dispute, not as a stand-alone action following an adoption. The Supreme Court of Missouri reversed the lower court’s judgments and dismissed the petition and related family access motion. View "In re A.L.P. and S.H.P." on Justia Law

The appellant was charged with driving while intoxicated in 2021 and the state sought to enhance his sentence by establishing that he was a chronic offender, which requires proof of four or more prior intoxication-related traffic offenses (IRTOs). To support this, the state introduced evidence of four prior offenses, including a 2002 municipal conviction for “driving while intoxicated” under the Joplin city code. The appellant contested the use of this 2002 offense, arguing the evidence did not prove beyond a reasonable doubt that it involved physically driving or operating a vehicle, as required by Missouri law at the time of the current offense.The Circuit Court of Jasper County admitted the 2002 municipal conviction into evidence and found the appellant to be a chronic offender, determining all four prior offenses qualified as IRTOs. The appellant was subsequently convicted by a jury for the current driving while intoxicated offense and sentenced as a chronic offender to seven years’ imprisonment. He appealed, arguing that only three of his prior offenses qualified as IRTOs and that he should have been sentenced as an aggravated offender rather than a chronic offender.The Supreme Court of Missouri reviewed the sufficiency of the evidence de novo. It held that the state failed to prove beyond a reasonable doubt that the 2002 municipal offense involved physically driving or operating a vehicle, since the record was silent as to the conduct underlying the offense and there was no evidence as to the elements of the municipal ordinance. Consequently, the court vacated the judgment sentencing the appellant as a chronic offender and remanded the case for resentencing as an aggravated offender. View "State v. Peters" on Justia Law

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