Justia Missouri Supreme Court Opinion Summaries

Articles Posted in Constitutional 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 sentencing Defendant to two terms of life imprisonment without the possibility of parole, holding that Mo. Rev. Stat. 565.020 is constitutional as applied to Defendant. Defendant was nineteen years old when he killed his grandparents. Defendant was convicted of two counts of first-degree murder and sentenced to death for each murder count. Later, a federal district court ordered the state of Missouri either to sentence Defendant to life without the possibility of probation or parole or grant him a new penalty phase trial. On remand, Defendant argued that section 565.020, which then provided that first-degree murder shall be punishable either by death or imprisonment for life without eligibility for probation or parole, was unconstitutional as applied to him because offenders who commit crimes at nineteen years old also display the transient, hallmark features of adolescence affecting risk and impulse control. The circuit court rejected Defendant's claims and sentenced him to life without the possibility of parole on both murder counts. The Supreme Court affirmed, holding that where Supreme Court precedent clearly defines a juvenile as an individual younger that eighteen years of age for purposes of the considerations Defendant sought, section 565.020 was constitutional as applied to Defendant. View "State v. Barnett" 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 granting summary judgment in favor of the State on the petition for declaratory and injunctive relief filed by Thomas Sager and the Missouri Coalition for the Environment (collectively, the Coalition) claiming Senate Bill No. 35 (SB 35), now codified at Mo. Rev. Stat. 34.030, violates the Missouri Constitution, holding that summary judgment was properly granted. In the petition, the Coalition claimed, among other things, that SB 35 violated the single-subject and clear-title requirements in Mo. Const. art. III, 23, that the bill's original purpose changed prior to final passage in violation of the original-purpose requirement of article III, section 21, that SB 35 implicitly amended other laws governing the Missouri Department of Natural Resources, and that the full text of those others laws should have been set out in the final bill pursuant to article III, section 28. The Supreme Court disagreed, holding that the SB 35 did not violate the state constitution in any of the ways argued by the Coalition. View "Missouri Coalition for Environment v. State" on Justia Law

Posted in: Constitutional 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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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 granting summary judgment in favor of the State and intervenors (collectively, Defendants) on the City of Chesterfield's action seeking a declaration that Mo. Rev. Stat. 66.600 and 66.620 are constitutionally invalid special laws, holding that sections 66.600 and 66.620 are not special laws. On appeal, Chesterfield argued that the trial court erred in failing to find that the statutes were constitutionally invalid special laws because the general assembly changed the population classification of section 66.600 to exclude St. Charles County, and that 66.620 creates a closed class based on immutable, historical, and geographic facts and is not substantially justified. The Supreme Court affirmed, holding that the circuit court did not err in granting summary judgment for Defendants because Defendants articulated a rational basis for the classifications in sections 66.600 and 66.200. View "City of Chesterfield v. State" on Justia Law

Posted in: Constitutional Law
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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