Justia Missouri Supreme Court Opinion Summaries

The Metropolitan St. Louis Sewer District (MSD) brought claims of inverse condemnation, trespass, and negligence against the City of Bellefontaine Neighbors for damages caused to MSD sewer lines during the course of a city street improvement project. The City moved to dismiss, alleging that inverse condemnation does not apply to public property and that sovereign immunity applied and had not been waived. The trial court entered judgment in favor of the City. The Supreme Court affirmed, holding that MSD failed to state an inverse condemnation claim, and sovereign immunity barred MSD’s tort claims against the City. View "Metro. St. Louis Sewer Dist. v. City of Bellefontaine Neighbors" on Justia Law

A police officer searched a plastic grocery bag that Defendant was holding after he was already handcuffed and seated in the police car. Inside the bag the officer discovered heroin. Defendant was charged with the class C felony of drug possession. Defendant filed a motion to suppress evidence of the heroin, arguing that neither the arrest nor the search of his plastic bag was lawful. The circuit court overruled the motion, and Defendant was convicted. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in overruling Defendant’s motion to suppress evidence of the heroin because (1) the arrest of Defendant was lawful; and (2) the search of Defendant’s bag was not a lawful search incident to arrest, but the exclusionary rule did not apply to this case. View "State v. Carrawell" on Justia Law

Appellant filed suit against Robinwood West Community Improvement District, alleging that Robinwood violated the Sunshine Law by not disclosing various public records, including those relating to Robinwood’s settlement of a personal injury lawsuit. Appellant also requested attorney fees and a civil penalty, asserting that Robinwood knowingly and purposely violated the Sunshine Law. The trial court entered judgment in favor of Appellant and ordered Robinwood to disclose the documents regarding the settlement agreement and the sums of money expended on the lawsuit. The court, however, denied Appellant’s request for attorney fees and a civil penalty. The Supreme Court reversed in part, holding that the trial court erred in concluding, as a matter of law, that Robinwood could not have knowingly or purposely violated the Sunshine Law. Remanded. View "Strake v. Robinwood W. Cmty. Improvement Dist." on Justia Law

Plaintiff was sixty-one years old when his employment with the Kansas City Chiefs was terminated. Plaintiff was replaced by a younger worker. Plaintiff filed a petition in the circuit court alleging a single act of age discrimination on the day of his termination. In pretrial proceedings, the trial court denied Plaintiff’s request to have testimony presented to the jury from numerous nonparty former employees over age forty who were either fired or pressured to resign and their job duties were assumed by younger replacements. The jury ultimately returned a verdict in favor of the Chiefs. The Supreme Court vacated the judgment, holding that the trial court (1) misapplied the legal standard for admission of evidence by so-called “me too” witnesses and abused its discretion in excluding “me too” evidence offered by the former employees; and (2) erred in excluding evidence concerning a discriminatory age-related statement allegedly made by a Chiefs executive and in quashing a deposition order issued to the Chiefs’ chairman and chief executive officer. Remanded. View "Cox v. Kansas City Chiefs Football Club, Inc." on Justia Law

Appellant, who was incarcerated, sought a dissolution of his marriage to his wife. The circuit court entered an order dismissing Appellant’s petition. Appellant appealed, challenging the constitutional validity of the application of Mo. Rev. Stat. 544.275 and Mo. Rev. Stat. 491.230 to him, asserting that these sections violated his right to due process because they denied him the right to be present in court to litigate his civil action and further denied him any reasonable alternatives to appearance in person. The Supreme Court transferred the appeal to the court of appeals, holding that Appellant failed to raise a real and substantial constitutional challenge to the validity of either statute so as to invoke the Court’s exclusive appellate jurisdiction. View "McNeal v. McNeal-Sydnor" on Justia Law

Defendant was charged with three counts of unlawful possession of a firearm. Defendant filed a motion to dismiss the unlawful possession charges, claiming that the felon-in-possession law violates the Missouri Constitution’s protection of his right to bear arms. The circuit court sustained the motion. The State appealed. While the appeal was pending, the Missouri Constitution’s right to bear arms provision - article I, section 23 - was amended to state that courts must apply strict scrutiny to laws restricting the right to bear arms. The Supreme Court reversed, holding (1) the prior version of article I, section 23 applies in this case; (2) as this Court held in Doston v. Kander, strict scrutiny applies under the prior version of article I, section 23; and (3) the felon-in-possession law survives strict scrutiny and does not violate article I, section 23’s protection of Defendant’s right to bear arms. Remanded. View "State v. Merritt" on Justia Law

After a jury trial, Defendant was convicted of unlawful possession of a firearm. Defendant appealed, arguing that the felon-in-possession law violates the Missouri Constitution’s protection of his right to bear arms. While Defendant’s appeal was pending, the Missouri Constitution’s right to bear arms provision - article I, section 23 - was amended to state that courts must apply strict scrutiny to laws restricting the right to bear arms. The Supreme Court affirmed Defendant’s conviction, holding (1) the prior version of article I, section 23 applies in this case; (2) as this Court necessarily held in Doston v. Kander, strict scrutiny applies under the prior version of article I, section 23; and (3) the felon-in-possession law survives strict scrutiny and does not violate article I, section 23’s protection of Defendant’s right to bear arms. View "State v. McCoy" on Justia Law

Mother was charged with felony child abuse after an investigation by Detective. Mother was ultimately acquitted. Mother subsequently brought this action against Detective for malicious prosecution and for violating 42 U.S.C. 1983. Detective moved for summary judgment on the basis of qualified immunity. The trial court sustained the motion. Mother appealed, arguing that Detective was not entitled to summary judgment because the statements he made in his probable cause affidavit were intentionally false or made with a reckless disregard for the truth. The Supreme Court affirmed, holding that Detective was entitled to qualified immunity on the malicious prosecution claim, where there was no evidence that he acted with malice, and on the section 1983 claim, where there was probable cause to believe that Mother had committed a criminal offense. View "Copeland v. Wicks" on Justia Law

After a jury trial, Defendant was convicted of second-degree murder and second-degree arson. The trial court sentenced Defendant to life imprisonment for the murder. Before the jury began deliberating, the trial court excused Juror 14, who was an alternate juror. After the jury had begun deliberating, Juror 12 was excused due to health concerns, and Juror 14 was substituted for Juror 12. Defendant appealed, arguing that the trial court improperly substituted Juror 14 after deliberations had begun. The Supreme Court reversed, holding that the trial court erred by substituting a discharged alternate juror after the jury had retired to consider its verdict, and the error deprived Defendant of his statutory right to have the same twelve jurors deliberate and decide his case. View "State v. Amick" on Justia Law

After a jury trial, Appellant was convicted of second-degree assault of a probation and parole officer. The court of appeals affirmed. Appellant subsequently filed a pro se Mo. R. Crim. P. 29.15 motion. The motion court appointed post-conviction counsel to represent Appellant in the proceeding. Ninety-one days later, Appellant’s appointed counsel filed an amended motion alleging claims of ineffective assistance of counsel. The amended motion was not timely. The motion court overruled the motion without holding an evidentiary hearing. The Supreme Court reversed because the motion court did not make an independent inquiry under Luleff v. State into whether Appellant was abandoned by appointed counsel when the untimely amended motion was filed. Remanded for an independent inquiry into whether Appellant was abandoned by appointed counsel. View "Moore v. State" on Justia Law