Justia Missouri Supreme Court Opinion Summaries

Articles Posted in Civil Rights
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The Supreme Court vacated the judgment of the circuit court convicting Defendant of one count of robbery in the first degree, holding that the circuit court erred in excluding expert witness testimony regarding various factors that can impact the reliability of eyewitness identification.The case against Defendant was largely based on the identification provided by the victim at a "show up" that occurred minutes after the crime occurred. After the state rested its case, Defendant's counsel sought to have an expert witness testify about he factors that can impact the reliability of eyewitness identifications generally. The trial court excluded the expert testimony. On appeal, arguing that the circuit court erred in excluding the testimony. The Supreme Court agreed, holding (1) the exclusion of the expert testimony deprived Defendant of his opportunity to present expert evidence about the most important issue the jury had to decide - whether the victim's identification of Defendant was mistaken; and (2) the likelihood that the expert testimony would have altered the outcome was too high to affirm Defendant's conviction. View "State v. Carpenter" on Justia Law

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In this disability discrimination action, the Supreme Court reversed the award of litigation expenses but affirmed in all other respects the circuit court's judgment in favor of Plaintiff, holding that no statute allows a circuit court to award as litigation expenses the expenses incurred by counsel for the prevailing party in a Missouri Human Rights Act (MHRA) case.Plaintiff sued the City of Kansas City for disability discrimination and retaliation under the MHRA. The jury returned a verdict in Plaintiff's favor, awarding him actual and punitive damages. The circuit court entered judgment in conformity with the verdict. Upon Plaintiff's motion, the circuit court amended the judgment to award attorney fees and litigation expenses. The Supreme Court affirmed in part and reversed in part, holding (1) the City's argument that the circuit court erred in admitting evidence and argument of Plaintiff's workers' compensation permanent partial disability rating was not preserved for appellate review; and (2) the circuit court erred in awarding Plaintiff litigation expenses because no statute authorizes an award of litigation expenses in an MHRA case. View "Wilson v. City of Kansas City" on Justia Law

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The Supreme Court vacated the judgment of the motion court overruling Appellant's pro se Rule 29.15 postconviction motion seeking to vacate his felony statutory sodomy conviction under Mo. Rev. Stat. 566.062, holding that there was no final judgment in the underlying criminal case, and therefore, Appellant's postconviction relief motion was premature.In his motion for postconviction relief, Appellant argued that he received ineffective assistance of trial counsel. After an evidentiary hearing, the motion court overruled the motion on the merits. Appellant appealed, arguing that his postconviction relief motion was premature because the trial court failed to carry out the Supreme Court's mandate issued in his direct appeal, and therefore, his judgment of conviction was not yet final. The Supreme Court agreed, holding (1) the trial court failure strictly to comply with the Court's mandate; and (2) therefore, the judgment of condition in Appellant's criminal case was not yet a final judgment that triggers the running of the time period in which he can file a Rule 29.15 motion, and the Rule 29.15 motion was premature. View "Lemasters v. State" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court judgment overruling Defendant's Mo. Rev. Stat. 29.15 motion for postconviction relief from his death sentence for first degree murder, holding that the circuit court's findings of fact and conclusions of law were not clearly erroneous.On appeal, Defendant argued that the circuit court committed multiple errors affecting the guilt phase, penalty phase, and postconviction relief phases of his criminal case. Among other things, Defendant argued that the circuit court erred in failing to find that his counsel provided ineffective assistance in several respects. The Supreme Court affirmed, holding that the circuit court's findings of fact and conclusions of law were not clearly erroneous and that the circuit court did not err in denying postconviction relief. View "McFadden v. State" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court committing Appellant to the department of mental health (DMH) as a sexually violent predator (SVP), holding that the circuit court did not err.In 2005, Appellant pleaded guilty to felony sex abuse. Before his release in 2016, the State filed a petition seeking to civilly commit him as an SVP. A jury found Appellant to be an SVP and the circuit court committed him to DMH. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion when it prohibited Appellant from questioning the jury panel about the specific ages of child victims; (2) the circuit court did not err when it excluded a portion of the testimony regarding Appellant's risk of future dangerousness; (3) the circuit court did not plainly err in submitting Instruction No. 6, the verdict director; (4) Appellant received effective assistance of counsel at his probable cause hearing; (5) the circuit court did not plainly err in overruling Appellant's motion for new trial based on juror nondisclosure of bias; (6) Appellant's claim of ineffective assistance of counsel for failure to move for change of venue was without merit; and (7) omissions in the trial transcript did not prejudice Appellant's appellate review. View "In re Care & Treatment of D.N." on Justia Law

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The Supreme Court affirmed the judgment of the circuit court to the extent it enjoined the State from prohibiting unobtrusive picketing about matters of public concern in negotiations for a new labor agreement with the CWA Local 6360, holding that Mo. Rev. Stat. 105.585(2)'s prohibition against "picketing of any kind" is unconstitutional, but severance of the phrase renders the provision constitutional.The circuit court enjoined the State from enforcing or implementing section 105.585(2)'s mandated prohibition against "picketing of any kind" in negotiating a collective bargaining agreement with certain public employees. In so holding, the circuit court declared section 105.585(2) unconstitutional under both the state and federal constitutions as it relates to picketing. The Supreme Court affirmed, holding (1) section 105.585(2) violates Mo. Const. art. I, 8; (2) severance of the portion of the statute prohibiting "picketing of any kind" is applicable and appropriate; and (3) permanent injunction was the appropriate remedy in this case. View "Karney v. Department of Labor & Industrial Relations" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court declaring the affidavit requirement of Mo. Rev. Stat. 115.427.2(1) and 115.427.3 unconstitutional and enjoining the State from requiring individuals who vote under the non-photo identification option provided in section 115.427.2(1) to execute the affidavit or in enjoining it from disseminating materials indicating photo identification is required to vote, holding that the circuit court did not err.Respondents filed a petition for declaratory and injunctive relief against the Missouri secretary of state, alleging that section 115.427 unconstitutionally burdens individuals' right to vote. The circuit court entered a judgment finding section 115.427 constitutional except for subsections 2(1) and 3, the affidavit requirement, and enjoined the State from requiring individuals who vote under this option to execute the affidavit required under subsections 2(1) and 3. The Supreme Court affirmed, holding (1) the affidavit requirement of sections 115.427.2(1) and 115.427.3 is misleading and contradictory, and therefore, the affidavit requirement is unconstitutional; and (2) the circuit court did not err in enjoining the affidavit requirement. View "Priorities USA v. State" on Justia Law

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In this suit alleging retaliation pursuant to section 213.070 of the Missouri Human Rights Act (MHRA) the Supreme Court reversed the judgment of the circuit court denying Washington University judgment notwithstanding the verdict (JNOV), holding that Plaintiff failed to submit a cognizable claim under the MRHA.Plaintiff filed a complaint against the University claiming that her request for a reasonable accommodation of her herniated discs was a protected activity. A jury returned a verdict in Plaintiff's favor against the University. The Supreme Court reversed, holding that the circuit court erred in overruling the University's JNOV motion because merely requesting an accommodation is insufficient to support a claim of retaliation under the plain language of the MHRA. View "Lin v. Ellis" on Justia Law

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The Supreme Court affirmed Defendant's conviction of felony possession of a controlled substance, holding that the circuit court did not err in admitting evidence obtained from Defendant's statements and a search of his vehicle after a traffic stop.On appeal, Defendant argued that the circuit court erred in overruling his motion to suppress because the traffic stop was unreasonable and violated the Fourth Amendment. The Supreme Court affirmed, holding (1) crossing the fog line and driving on the shoulder is a traffic violation and creates a lawful justification for a traffic stop; and (2) the stop in this case was justified after Defendant's vehicle crossed the fog line and drove on the shoulder and therefore did not constitute an unreasonable seizure under the Fourth Amendment. View "State v. Smith" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's claims for relief under the Missouri Human Rights Act (MHRA) for age discrimination and retaliation, holding that the Court was precluded from applying the MHRA to Appellant's claims.Respondent filed a motion to dismiss Appellant's claim, arguing that his petition did not state a claim upon which relief could be granted because the MHRA does not apply to an Illinois employee who faced alleged discriminatory acts in Illinois. The circuit court dismissed the petition with prejudice. The Supreme Court affirmed, holding that because Appellant was aggrieved solely in Illinois, the express language of the MHRA, coupled with the presumption against extraterritorial application of laws, precluded that Court from applying the MHRA to Appellant's claims. View "Tuttle v. Dobbs Tire & Auto Centers, Inc." on Justia Law