Justia Missouri Supreme Court Opinion Summaries

The City of St. Louis appealed the trial court's holding that the prohibition against special laws contained in Mo. Const. art. III, 40 was not violated by Mo. Rev. Stat. 320.097. That statute exempted certain veteran firefighters who lived in areas with unaccredited or provisionally accredited school districts from any local laws requiring them to live in their home district. The State also appealed, alleging (1) the trial court erred in holding that section 320.097 violated what the trial court believed was the "broad measure of complete freedom from State legislative control" given to constitutional charter cities by the Missouri Constitution, and (2) the trial court erred in holding that the statute violated the equal protection clauses of the Missouri and U.S. constitutions because it was not rationally related to any legitimate purpose. The Supreme Court (1) affirmed the trial court's holding that the statue was not a special law in violation of the Missouri Constitution; (2) reversed the trial court's holding that the statute violated the state constitution because it interfered with the City's right to set its employees' and officers' powers, duties and compensation; and (3) reversed the trial court's holding that the statute violated equal protection guarantees. View "City of St. Louis v. State" on Justia Law

A jury found Appellant guilty of four counts of first-degree murder and armed criminal action for the shooting deaths of his girlfriend and her three children. Appellant was sentenced to death for his crimes. Appellant subsequently filed a motion for post-conviction relief, alleging ineffective assistance of counsel. After an evidentiary hearing regarding some of Appellant's claims, the motion court overruled his motion. The Supreme Court affirmed, holding that Appellant failed to make a sufficient showing to support Strickland v. Washington's prejudice prong because of the overwhelming evidence presented that established his guilt, and therefore, the motion court did not err in overruling the motion. View "Taylor v. State" on Justia Law

Appellant was found guilty by a jury of robbery in the first degree, armed criminal action, and unlawful use of a weapon. The appellate court affirmed. Appellant filed a Mo. R. Crim. P. 29.15 motion, alleging his trial counsel was ineffective for not calling a witness to testify and because his appellate counsel was ineffective in failing to raise a meritorious issue on appeal. The circuit court overruled Appellant's motion without a hearing. The Supreme Court affirmed because (1) the testimony of the witness did not negate an element of the crime and would not produce a viable defense, and (2) Williams could not demonstrate a reasonable probability that the outcome wold have been different had his appellate counsel raised the sufficiency of the evidence claim on appeal. View "Williams v. State" on Justia Law

Appellant was found guilty by a jury of the unlawful use of a weapon pursuant to Mo. Rev. Stat. 571.030.1. Appellant appealed, arguing that the circuit court erred in overruling his motion for a judgment of acquittal because there was insufficient evidence presented at trial that the weapon was concealed and that the weapon was a functional lethal weapon. The Supreme Court granted transfer after opinion by the court of appeals. The Court then affirmed the circuit court's judgment, holding (1) the evidence was sufficient to find Appellant concealed the firearm on or about his person; and (2) section 571.030.1 does not require the State to introduce evidence of the firearm's "functionality" in order to gain a conviction for the unlawful use of a weapon. View "State v. Wright" on Justia Law

Defendant was convicted and sentenced to twelve years without probation or parole for the class A felony of trafficking drugs in the first degree. On appeal, Defendant claimed, inter alia, that the trial court erred in overruling his objection to a verdict-directing instruction because it did not require the jury to find Defendant knew of the substance's content and character. The Supreme Court reversed, holding (1) the trial court's failure to instruct the jury to find that Defendant knew the content or character of the drugs relieved the State of its burden of proving each element of the offense beyond a reasonable doubt; and (2) this failure was plain error and required the reversal of Defendant's conviction and sentence. Remanded for a new trial. View "State v. Stover" on Justia Law

As a state employee, Laurel Beard was a member of the Missouri State Employees' Retirement System (MOSERS). Beard filed for retirement but died before her annuity start date. Following Beard's death, Plaintiffs, Beard's assigned heirs, requested MOSERS to distribute Beard's retirement benefits to them as Beard's designated beneficiaries. MOSERS' board of trustees determined Plaintiffs were not entitled to retirement or survivor benefits because Beard died prior to her annuity starting date and did not have a surviving spouse or dependent children. Plaintiffs filed suit, seeking review of the MOSERS decision denying benefits. The trial court entered judgment in favor of MOSERS. Plaintiffs appealed, alleging the trial court wrongly interpreted Mo. Rev. Stat. 104.1030 in denying them retirement benefits. The Supreme Court affirmed, holding (1) the trial court properly applied the plain language of section 104.1030; and (2) section 104.1030 is constitutional for vested members of MOSERS who have filed for retirement but die before their annuity start date. View "Beard v. Mo. State Employees' Ret. Sys." on Justia Law

The Missouri Department of Corrections appealed the trial court's judgment in favor of Respondent on her claim of disability discrimination under the Missouri Human Rights Act (MHRA). On appeal, the Department claimed the trial court erred in overruling its objection to Respondent's verdict director because it did not include an essential element of her discrimination claim and erred in calculating punitive damages under Mo. Rev. Stat. 510.265. The Supreme Court reversed because the verdict-directing instruction did not require the jury to find that Respondent was disabled, an essential element of her MHRA claim. The Court also held that the trial court's calculation of punitive damages was the correct application of section 510.265. View "Hervey v. Dep't of Corrections" on Justia Law

David and Glenette Nothum sought a writ prohibiting the circuit court from compelling them to testify in a judgment debtor's examination conducted pursuant to Mo. Rev. Stat. 513.380. The court ordered the Nothums to testify despite their assertion of the privilege against self-incrimination and held them in contempt when they refused to do so, finding that the immunity granted to the Nothums pursuant to section 513.380.2 was coextensive with their constitutional privilege. The Supreme Court granted a permanent writ of prohibition, holding that the trial court abused its discretion in ordering the Nothums to testify, as the immunity in this case did not include derivative use immunity and, so, was not coextensive with the Nothums' constitutional privilege. View "State ex rel. Nothum v. Circuit Court (Walsh) " on Justia Law

The Missouri Public Defender Commission petitioned the Supreme Court for a writ of prohibition ordering the trial court to withdraw its appointment of the public defender's office to represent Defendant, alleging that the appointment violated 18 C.S.R. 10-4.010 (the rule). The rule, promulgated by the Commission, adopts a "caseload protocol" that permits a district defender office to decline additional appointments when it has been certified as being on limited availability after exceeding its caseload capacity for at least three consecutive calendar months. The trial court did not refuse to apply the rule, but rather, the trial court said it believed it had no choice but to appoint a public defender because to do otherwise would have violated Defendant's Sixth Amendment right to counsel, as the court could identify no other realistic mechanism by which to provide other counsel. The Supreme Court ordered the trial court to vacate its order, holding that the court erred by (1) determining that the Sixth Amendment requires appointment of counsel without regard to whether counsel would be able to offer competent representation; (2) failing to apply the rule; and (3) holding that the rule provides no realistic alternative mechanisms for handling the issue of excessive appointments. View "State ex rel. Mo. Pub. Defender Comm'n v. Circuit Court" on Justia Law

David Miller was convicted of six sexual offenses against his minor daughter and was sentenced to terms of imprisonment. The Supreme Court reversed the judgment with respect to Miller's convictions for first-degree statutory sodomy, deviate sexual assault, and first-degree child molestation, holding (1) there was insufficient evidence Miller committed the charged offenses of first-degree statutory sodomy and deviate sexual assault during the charged period of December 3, 2004 through December 3, 2005, and thus Defendant's double jeopardy rights were implicated; and (2) the circuit court plainly erred in submitting a verdict director to the jury allowing the jury to find Defendant guilty of the crime of first-degree child molestation for an act that was not criminal during the charged period. Affirmed in all other respects. Remanded. View "State v. Miller" on Justia Law