Justia Missouri Supreme Court Opinion Summaries

The Supreme Court of Missouri dismissed an appeal from the City of Harrisonville and Brad Ratliff (collectively, "the City"), who were challenging a ruling by the lower court in favor of the Missouri Department of Natural Resources ("MDNR") and the Board of Trustees for the Petroleum Storage Tank Insurance Fund ("the Fund Board"). The case was initially about the City's requests for certain documents related to the conduct of the executive director of the Fund, which the MDNR and the Fund Board had refused to disclose, citing several Missouri statutes. The City alleged that the MDNR had knowingly violated Missouri's Sunshine Law. The circuit court granted summary judgment to the MDNR and the Fund Board, and the court of appeals affirmed that judgment. The City then appealed to the Supreme Court of Missouri. However, the Supreme Court dismissed the appeal due to the City's failure to properly brief any allegations of reversible error, as required by Rule 84.13(a), and the City's failure to comply with the basic requirements of Rule 84.04(d). The court noted that the City's points of contention did not follow the required format and failed to identify any claim of reversible error in the circuit court's judgment. The court also pointed out that there is no right to appeal from a court of appeals decision, and such a claim is categorically unreviewable. Even if the court had decided to review the City's appeal, the circuit court's judgment would have been affirmed because the City only purported to appeal the summary judgment based on one subsection of § 610.021, while summary judgment was granted on two subsections of that statute. View "City of Harrisonville v. Missouri Dept. of Natural Resources" on Justia Law

The Supreme Court made permanent a preliminary writ it issued granting Monsanto Company's petition for a writ of prohibition or mandamus requiring the St. Louis circuit court to transfer venue of five of the six plaintiffs' claims, holding that Missouri law compelled this result.Plaintiffs brought this action claiming that they were injured as a result of exposure to a herbicide manufactured by Monsanto Company and seeking monetary damages. Monsanto filed a motion to transfer venue as to five of the six plaintiffs in this case to St. Louis County but failed to file a motion to transfer in the six plaintiff's case The circuit court subsequently consolidated Plaintiffs' individual claims. Monsanto filed a motion to reconsider, arguing that venue was inappropriate in St. Louis Valley. The circuit court overruled the motion, after which Monsanto sought relief by way of mandamus or prohibition. The Supreme Court granted relief, holding that Mo. Rev. Stat. 508.010.5(1) mandated that venue shall be where Monsanto's registered agent was located as of filing - St. Louis County. View "State ex rel. Monsanto Co. v. Honorable Mullen" on Justia Law

The Supreme Court reversed the judgment of the circuit court sustaining the State's motion for judgment on the pleadings and dismissing Plaintiffs' action seeking a declaration that the Second Amendment Protection Act (SAPA), Mo. Rev. Stat. 1.410 through 1.485, is unconstitutional and requesting injunctive relief, holding that Plaintiffs had no adequate remedy at law other than to pursue their declaratory judgment action.Plaintiffs - the City of St. Louis, St. Louis County, and Jackson County - brought this action challenging SAPA. The State filed a motion for judgment on the pleadings, alleging that Plaintiffs had adequate remedies at law. The circuit court sustained the motion, finding that Plaintiffs had an adequate remedy at law because multiple individual lawsuits were pending in which Plaintiffs could bring their constitutional challenges. The Supreme Court reversed, holding that Plaintiffs lacked an adequate remedy at law in which to adjudicate their specific constitutional challenges. View "City of St. Louis v. State" on Justia Law

The Supreme Court made permanent a preliminary writ of prohibition preventing the circuit court from allowing Plaintiffs' claims against Janssen Pharmaceuticals, Johnson & Johnson, and Janssen Research & Development (collectively, Defendants) in the Circuit Court of the City of St. Louis, holding that the circuit court abused its discretion by refusing to transfer the claims of those injured outside of the City of St. Louis.Multiple plaintiffs filed this action stating various causes of action arising from the sale and use of Risperdal, a prescription drug. Defendants filed a motion to dismiss based on improper venue and forum non conveniens for all plaintiffs not injured in the City of St. Louis. The circuit court overruled the motion. Defendants then filed a petition for a writ of prohibition or mandamus asking that the claims of the plaintiffs whose injuries allegedly occurred in Missouri counties other than the City of St. Louis be transferred. The Supreme Court granted a writ of prohibition, holding (1) Mo. R. Civ. P. 52.05(a) cannot be used to confer venue in a forum that is otherwise improper, and newly enacted Mo. Rev. Stat. 508.013.1 did not alter the result on these facts; and (2) the circuit court's failure to transfer the claims of those injured outside of the City of St. Louis was an abuse of discretion. View "State ex rel. Janssen Pharmaceuticals, Inc. v. Honorable Michael Noble" on Justia Law

The Supreme Court made permanent a preliminary writ of mandamus sought by Vacation Management Solutions, LLC (VMS) to prevent the circuit court from moving forward with Kyle Klosterman's case in the City of St. Louis, holding that the action must be transferred pursuant to Mo. R. Civ. P. 51.045(c).Klosterman filed an action against VMS in the Circuit Court of the City of St. Louis alleging violations of the Missouri Merchandising Practices Act. VMS filed both a motion to dismiss and a motion to transfer venue, arguing that the City of St. Louis was an improper venue and that venue was proper in either Warren County or in St. Charles County. The circuit court overruled the motion to dismiss. Thereafter, VMS filed a petition for a writ of prohibition. The Supreme Court granted the writ, holding that because Klosterman did not reply within thirty days to VMS's motion to transfer alleging improper venue, the circuit court was required to transfer the case to Warren County or St. Charles County. View "State ex rel. Vacation Management Solutions, LLC v. Honorable Joan L. Moriarty" on Justia Law

The Supreme Court made permanent its preliminary writ of prohibition prohibiting the circuit court from ordering certain defendants to be joined as necessary parties, holding that Mo. R. Civ. P. 52.04(a) did not mandate that the added defendants be joined.After deficiencies in the construction of an independent senior living facility (the Project) were discovered, Plaintiff brought contract and tort claims against the architect, the structural engineer, the construction company, the framer, and the supplier, alleging construction defects. The masonry company hired to perform brick masonry work was not included as a defendant. Certain defendants moved to add the masonry company, arguing that the company must be added pursuant to Rule 52.04. The circuit court ordered the masonry company be joined. Plaintiff filed a petition for a writ of prohibition seeking to direct the circuit court to dismiss and remove the masonry company. The court of appeals denied the petition. The Supreme Court granted the petition, holding that the masonry company was not a "necessary" defendant, and therefore, the circuit court did not have the authority to require joinder. View "State ex rel. Woodco, Inc. v. Honorable Jennifer Phillips" on Justia Law

The Supreme Court made permanent its preliminary writ of mandamus compelling the circuit court to transfer the underlying lawsuit to St. Charles County, holding that the circuit court had no authority to change venue and transfer the case from St. Charles County to St. Louis County.Universal Credit Acceptance, Inc. (UCA) filed the underlying lawsuit in St. Charles County seeking to recover a judgment arising from Renwick Ware's alleged default on a retail sales installment contract. After the associate circuit division sustained Ware's application for change of judge, Ware filed a motion to change the venue to St. Louis County. The circuit court sustained the motion and transferred the case to St. Louis County. UCA filed a petition for a writ of mandamus, arguing that, pursuant to Rule 51.06(a), Ware waived the right to file a motion to change venue because the motion was not consolidated with his application for change of judge. The Supreme Court issued a preliminary writ that it made permanent, holding that Ware's motion to change venue was improper under Rule 51.06(a), and therefore, UCA demonstrated a clear and unequivocal right to have the case retransferred to St. Charles County. View "State ex rel. Universal Credit Acceptance, Inc. v. Honorable Reno" on Justia Law

The Supreme Court made permanent a preliminary writ sought by LG Chem, Ltd. to prohibit the circuit court from enforcing its over overruling LG Chem's motion to dismiss for lack of personal jurisdiction, holding that due process prohibited Missouri courts from asserting personal jurisdiction over LG Chem in this matter.LG Chem, a Korean company with its headquarters in Seoul, South Korea, manufactured model 18650 lithium-ion batteries. Peter Bishop sued LG Chem in the St. Louis County circuit court alleging that he purchased one of LG Chem's batteries in a store located in St. Peters, Missouri for use in his e-cigarette. Bishop alleged that the battery spontaneously exploded in his pocket, resulting in burn injuries. LG filed a motion to dismiss for lack of personal jurisdiction. The circuit court overruled the motion on the merits. LG then sought a writ of prohibition. The Supreme Court issued a preliminary writ of prohibition. The Court then made its preliminary writ permanent with directions to the circuit court to vacate its order overruling LG Chem's motion to dismiss for lack of personal jurisdiction, holding that LG Chem lacked sufficient minimum contacts with the state of Missouri, and therefore, the assertion of personal jurisdiction over LG Chem would violate due process. View "State ex rel. LG Chem, Ltd. v. Honorable McLaughlin" on Justia Law

The Supreme Court dismissed these appeals for lack of jurisdiction because neither appeal challenged a "final judgment" as that phrase is used in Mo. Rev. Stat. 512.020(5).The treasurer appealed from a declaratory order. The State appealed from a circuit court order sustaining a motion for summary judgment on the State's cross-claim and also appealed from an injunctive order. The Supreme Court dismissed the appeals for lack of jurisdiction, holding (1) the declaratory order was not a judgment, let alone a final judgment; and (2) neither of the two orders that the State appealed from was a final judgment as that phrase is used in section 512.020(5) in that neither disposed of a "judicial unit" of claims. View "Wilson v. City of St. Louis" on Justia Law

The Supreme Court made permanent a preliminary writ of prohibition prohibiting the Jefferson County circuit court from taking any further action except to transfer the underlying action to Cole County, where venue was proper.Jefferson County 9-1-1 Dispatch filed this declaratory judgment action against the Director of the Missouri Department of Revenue in the Jefferson County circuit court seeking a declaration as to the meaning of subsections 5 and 6 of Mo. Rev. Stat. 190.460 and to enjoin the Director from applying section 190.460 to Dispatch. The Director filed a motion to change venue to the Cole County circuit court alleging that Cole County was the proper venue pursuant to Mo. Rev. Stat. 508.010.2, the general venue statute. The circuit court overruled the Director's motion. The Director then filed a petition for a writ of prohibition in the court of appeals, which ultimately denied the writ. The Director then sought a writ of prohibition from the Supreme Court. The Court issued a preliminary writ, which it made permanent, holding that venue was improper in Jefferson County and proper in Cole County. View "State ex rel. Zellers v. Honorable Stacey" on Justia Law