Justia Missouri Supreme Court Opinion Summaries

Bohr Farms owned and operated a concentrated animal feeding operation (CAFO) that accommodated more than 4,000 hogs. Cargill Pork, LLC owned the hogs. Appellants, several landowners and other individuals, brought this action against Cargill and Bohr Farms (together, Respondents), alleging damages for temporary nuisance, negligence, and conspiracy due to alleged offensive odors that emanated from the CAFO. Appellants did not claim damages for diminution in rental value or documented medical costs as authorized by Mo. Rev. Stat. 537.296.2, but, rather, alleged that their damages for temporary nuisance consisted solely of the loss of use and enjoyment of their property. The circuit court granted summary judgment in favor of Respondents, concluding, inter alia, that section 537.296 was constitutional and did not authorize an award of damages for Appellants’ alleged loss of use and enjoyment of their property. The Supreme Court affirmed, holding (1) section 537.296 is constitutional; and (2) Appellants’ nuisance, conspiracy and vicarious liability claims are inseparable from the nuisance allegations and are therefore barred by section 537.296.6(1). View "Labrayere v. Bohr Farms, LLC" on Justia Law

After a jury trial, Defendant was found guilty of two counts of first-degree murder, one count of forcible rape, one count of forcible sodomy, and five counts of armed criminal action. Defendant received two death sentences for the murder convictions. The Supreme Court affirmed, holding that the trial court did not err in (1) failing to stop the trial and order a competency evaluation, as Defendant did not meet his burden of demonstrating that he was not competent to stand trial; (2) granting Defendant’s requests to not remain in the courtroom during certain phases of his trial; (3) finding Defendant voluntarily waived his right to testify during both the guilt and penalty phases of his trial; (4) overruling Defendant’s motion for a continuance to be medicated; (5) denying the jury’s request to view all of the exhibits admitted into evidence during the penalty phase; and (6) admitting victim impact testimony and evidence. Finally, the Court held that the imposition of the death penalty met the statutory requirements. View "State v. Driskill" on Justia Law

Defendant was charged with murder in the first degree, assault in the first degree, and two counts of armed criminal action. On the day of trial, after the trial court denied the state’s request to reconsider granting a continuance, the state dismissed the case nolle prosequi. Later that day, the state filed a new complaint with the same charges against Defendant. Defendant filed a motion to dismiss based on a violation of his right to a speedy trial. The trial court overruled the motion to dismiss. After a trial, Defendant was convicted of the charges. The Supreme Court affirmed, holding that the trial court did not err in (1) not designating the state’s nolle prosequi as a dismissal with prejudice because the court did not have authority to do so; and (2) overruling Defendant’s motion to dismiss, as no prejudice resulted from the delay, and therefore, Defendant’s right to a speedy trial was not violated. View "State v. Sisco" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder, armed criminal action, first-degree burglary, and unlawful possession of a firearm by a felon. Defendant was sentenced to death for the murder charge. The Supreme Court affirmed, holding (1) even assuming the police violated Defendant’s Fourth Amendment rights, evidence seized from Defendant’s person and car was admissible because Defendant’s flight and the nature of the alleged violation purged the evidence of any taint of an illegal stop; (2) there was sufficient probable cause to support a search warrant for Defendant’s apartment; (3) evidence of other weapons and ammunition unrelated to the crime was relevant and therefore admissible; (4) the victim’s statements on an application for a protective order and to her landlord about Defendant were admissible under the forfeiture by wrongdoing doctrine; (5) a note found in Defendant’s car was authenticated by circumstantial evidence; (6) there was sufficient evidence to support Defendant’s conviction for first-degree burglary; and (7) Defendant’s sentence was proportional. View "State v. Hosier" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree statutory sodomy, two counts of second-degree statutory sodomy, and one count of attempted first-degree child molestation. The Supreme Court reversed, holding (1) one juror committed misconduct by intentionally withholding material information related to the lawsuit, specifically that the juror formed an opinion about Defendant’s guilt or innocence during voir dire in direct contravention of the circuit court’s instructions that he was prohibited from forming or expressing any opinion about the case; and (2) the evidence was insufficient to convict Defendant of attempted first-degree child molestation. View "State v. Ess" on Justia Law

Appellant was convicted and sentenced for two counts of first-degree murder and sentenced to death on each count. The Supreme Court affirmed the convictions and sentences. Appellant subsequently filed a pro se motion to vacate his convictions and sentences pursuant to Mo. R. Crim. P. 29.15, claiming that he received ineffective assistance of counsel at trial and that the state failed to disclose exculpatory evidence. The motion judge overruled Appellant’s motion. The Supreme Court affirmed, holding (1) Appellant’s claims relating to the disclosure and investigation of an autosomal DNA profile were not preserved for review; and (2) the motion court did not clearly err in overruling Appellant’s Brady violation claim and ineffective assistance of counsel claims. View "Dorsey v. State" on Justia Law

After a jury trial, Defendant was found guilty of first degree murder. Defendant was sentenced to death. The Supreme Court affirmed the conviction and sentence, holding (1) the circuit court did not err in overruling Defendant’s motion to suppress certain statements he made and physical evidence and admitting them at trial; (2) the circuit court did not abuse its discretion or make inconsistent rulings in the admissibility of evidence at the suppression hearing; (3) the evidence amply supported a first-degree murder conviction; (4) the circuit court did not abuse its discretion in overruling Defendant’s objections and admitting during trial several pieces of evidence and several crime scene and autopsy photographs; (5) the prosecutor did not commit misconduct during closing arguments; and (6) Defendant’s death sentence was proportional to the crime. View "State v. Collings" on Justia Law

Appellant pleaded guilty to two felony counts of first-degree statutory sodomy. Appellant subsequently filed a Mo. R. Crim. P. 24.035 motion for post-conviction relief. The motion court appointed post-conviction counsel to represent Appellant in the proceeding. Appointed counsel then filed a motion requesting that the appointment of counsel be rescinded on the basis that Appellant’s Rule 24.035 motion was untimely. Without holding an independent inquiry, the motion court rescinded its previous order appointing counsel and dismissed the case with prejudice, finding that the motion was not timely filed. Thereafter, Appellant filed a motion to reopen his post-conviction proceedings, claiming that he was abandoned by his appointed counsel when his counsel failed to investigate the timeliness of his post-conviction motion before filing the motion to rescind appointment of counsel. The motion court overruled Appellant’s motion. The Supreme Court reversed, holding that the motion court clearly erred in dismissing Appellant’s motion because the record raised the presumption that Appellant was abandoned by his post-conviction counsel. View "Vogl v. State" on Justia Law

After a jury trial, Appellant was convicted of one count of child molestation and sentenced to fourteen years’ imprisonment. Appellant’s conviction was affirmed on appeal. Appellant subsequently filed a pro se motion for post-conviction relief, setting forth ten allegations of error. After an evidentiary hearing, the motion court denied post-conviction relief. The Supreme Court affirmed, holding that Appellant failed to establish that his trial counsel and appellate counsel were ineffective for failing to challenge the molestation verdict directors, as Appellant’s claims of error were either waived or without merit. View "Mallow v. State" on Justia Law

John C. Middleton, an inmate under a sentence of death, was scheduled to be executed on July 16, 2014. After Middleton’s execution was scheduled to occur, Middleton field a petition for a writ of habeas corpus asserting that his execution would violate the Eighth Amendment because he was incompetent to be executed. The Supreme Court denied Middleton’s habeas petition on the merits because Middleton failed to make a substantial threshold showing that he lacked the competence to be executed and therefore was not entitled to a full hearing to determine his competence. View "Middleton v. Russell" on Justia Law