Justia Missouri Supreme Court Opinion Summaries

Articles Posted in Civil Rights
by
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

by
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

by
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

by
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

by
The Supreme Court quashed a preliminary writ of prohibition it issued directing the circuit court to vacate a portion of its order overruling Relator's motion to dismiss and to dismiss the underlying plaintiff's petition with prejudice for failure to state a claim upon which relief could be granted, holding that Plaintiff had an adequate remedy by way of appeal. Plaintiff filed a complaint of discrimination alleging violations of the Missouri Human Rights Act (MHRA). The circuit court concluded that Plaintiff stated a claim under the MHRA and denied Relator's motion to dismiss. Relator sought a writ of prohibition directing the circuit court to vacate the portion of its order overruling Relator's motion to dismiss. The Supreme Court issued a preliminary writ of prohibition. At the time, the lower courts did not have the benefit of the Supreme Court's opinion in Tuttle v. Dobbs Tire & Auto Centers, Inc., __ S.W.3d __ (Mo. banc 2019). The Supreme Court then quashed the preliminary writ, holding that the MHRA did not provide Plaintiff with relief and that, as demonstrated by Tuttle, Relator may seek relief by appeal after a final judgment. View "State ex rel. Anheuser-Busch, LLC v. Honorable Joan L. Moriarty" on Justia Law

Posted in: Civil Rights
by
The Supreme Court affirmed the judgment of the motion court denying Defendant's motion for postconviction relief filed under Mo. R. Crim. P. 29.15, holding that the motion court did not err in denying postconviction relief. Defendant was convicted of murder in the first degree, armed criminal action, burglary in the first degree, and unlawful possession of a firearm by a felon. The trial court sentenced Defendant to death. Defendant later moved for postconviction relief, alleging ineffective assistance of counsel. The motion court denied the postconviction motion. The Supreme Court affirmed, holding that the motion court did not err in denying Defendant's claims. View "Hosier v. State" on Justia Law

by
The Supreme Court reversed the judgment of the motion court to the extent it overruled Appellant's motion for postcondition relief on his driving while revoked conviction and affirmed the judgment in all other respects, holding that appellate counsel's failure to raise a sufficiency of evidence claim constituted deficient performance that prejudiced Appellant. Appellant was convicted of driving while intoxicated and driving while revoked. In his Mo. R. Civ. P. 29.15 motion for postconviction relief Appellant argued that his trial counsel was ineffective for failing to call his physician to testify that certain prescription medications he took made him appear intoxicated by alcohol the night he was arrested and that appellate counsel was ineffective for failing to argue there was insufficient evidence to enhance his driving while revoked misdemeanor to a felony. The Supreme Court agreed and reversed in part, holding (1) Appellant's postconviction relief claim relating to his driving while intoxicated conviction was properly denied because there was no reasonable probability the trial court's finding would have been different had the physician testified at Appellant's trial; and (2) appellate counsel's failure to raise the sufficiency of the evidence claim constituted deficient performance by which Appellant was prejudiced. View "Hounihan v. State" on Justia Law

by
The Supreme Court affirmed the judgment of the motion court overruling Defendant's Rule 29.15 motion for post conviction relief without an evidentiary hearing, holding that Defendant failed to plead facts showing his counsel was ineffective. In his Rule 29.15 motion Defendant claimed that his trial counsel provided ineffective assistance by failing to seek suppression of methamphetamine found during a warrantless search of a cigarette pack seized from his pocket on the grounds that the search occurred thirty minutes after his arrest in an area outside his immediate control. The motion court overruled the motion. The Supreme Court affirmed, holding that the search of Defendant's cigarette was a lawful search incident to arrest, and therefore, Defendant failed to plead facts showing his counsel was ineffective in not challenging the search. View "Greene v. State" on Justia Law

by
In this appeal from the circuit court's finding that D.C.M. committed an act that, if committed by an adult, would have constituted the felony of making a terrorist threat in the second degree, the Supreme Court remanded this case to the circuit court for an evidentiary hearing to determine whether counsel was ineffective and otherwise affirmed the judgment, holding that the record was insufficient to determine whether counsel was ineffective. D.C.M. was sitting in a school cafeteria when he told another student that he felt like "blowing the school up" or wanted to see how it felt to "shoot the school up." Based on this evidence, the circuit court placed D.C.M. in the custody of the division of youth services for an indefinite term. The Supreme Court held (1) D.C.M.'s ineffective assistance of counsel claims could not be addressed on direct appeal because the record was insufficient to address these claims; (2) the circuit court did not abuse its discretion in denying counsel's request for a continuance; and (3) there was sufficient evidence for the circuit court to find beyond a reasonable doubt that D.C.M. committed an act which, if committed by an adult, would have constituted the felony of making a terrorist threat in the second degree. View "D.C.M. v. Pemiscot County Juvenile Office" on Justia Law

by
The Supreme Court affirmed the judgment of the circuit court finding Defendant guilty of the first-degree murder of a ten-year-old girl and sentencing him to death, holding that none of Defendant's assignments of error warranted reversal. Specifically, the Court held that the circuit court did not abuse its discretion by (1) overruling Defendant's objection to the admission of photographs from the victim's cellphone; (2) admitting gun evidence found in Defendant's home; (3) admitting the contents of a folder containing photos of Defendant's female, middle school students and accounts of fictional sexual encounters with thirteen-year-old girls; (4) admitting victim impact evidence; (5) permitting the State to argue during closing argument that the jury could speak for the victim and her family by sentencing Defendant to death; and (6) sustaining the State's motion to strike a venire person for cause during the death qualification voir dire. Further, Defendant's constitutional arguments were unavailing, and Defendant's death sentence met all the statutory requirements. View "State v. Wood" on Justia Law