Justia Missouri Supreme Court Opinion Summaries

After the General Assembly enacted HB 1171, which amended Mo. Rev. Stat. 67.320 to permit any first-class county within a certain population range to establish a county municipal court division, the Franklin County Commission entered a county order establishing a municipal court division pursuant to the amended section 67.320. Taxpayers of Franklin County sued the members of the Commission, alleging that HB 1171’s enactment violated constitutional prohibitions against multiple subjects and change of original purpose and that the Commission’s order was void. On remand, the trial court concluded that HB 1171’s enactment was constitutional. While Taxpayers’ appeal was pending, the General Assembly passed SB 621, which repealed and reenacted section 67.320, including the language regarding establishment of a municipal court division. The Supreme Court dismissed the appeal as moot, as Taxpayers’ appeal no longer represented an actual controversy. View "LeBeau v. Comm’rs of Franklin County" on Justia Law

After a jury trial, Cecil Clayton was found guilty of first-degree murder and sentenced to death. After unsuccessfully pursuing an appeal and post-conviction relief, Clayton filed a federal petition for a writ of habeas corpus, which the federal district court denied. The U.S. Supreme court affirmed that decision. On February 6, 2015, this Supreme Court scheduled the execution of Clayton. Clayton filed a petition for writ of habeas corpus claiming he was not competent to be executed under Ford v. Wainwright, Panetti v. Quarterman, and Mo. Rev. Stat. 552.060.1. The Supreme Court denied Clayton’s petition for writ of habeas corpus and overruled as moot Clayton’s accompanying motion for a stay of execution, holding (1) Clayton was competent to be executed under Ford and Panetti and met the standard for competence in section 552.060.1; (2) Mo. Rev. Stat. 552.060.2 is not unconstitutional; and (3) Clayton is not intellectually disabled under Missouri law and therefore not categorically excluded from eligibility for the death penalty. View "State ex rel. Clayton v. Griffith" 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

This case centered on a petition to dissolve a same-sex marriage. The circuit court, sua sponte, dismissed the action on grounds that it lacked subject matter jurisdiction and constitutional and statutory authority to dissolve a same-sex marriage due to the state constitutional and statutory bans on same-sex marriage. The Supreme Court reversed, holding that the circuit court had subject matter jurisdiction because the plain language of Mo. Const. art. V, 14 provides that Missouri circuit courts have jurisdiction over all civil cases and matters, and a petition for dissolution of marriage is a civil case or matter falling within the jurisdiction of the circuit court. View "In re Marriage of M.S." 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

In 2012, St. Louis County adopted an ordinance that implemented a foreclosure mediation program requiring lenders to provide residential borrowers an opportunity to mediate prior to foreclosure. Two bankers filed suit against the County seeking a declaratory judgment establishing that the ordinance was invalid. The circuit court sustained the County’s motion for summary judgment, concluding that the County possessed the charter authority to enact the ordinance, the ordinance was a valid exercise of the County’s police power, the ordinance was not preempted by state law, and the fees associated with the ordinance did not violate the Hancock Amendment. The Supreme Court reversed, holding that the ordinance was void and unenforceable ab initio because the County exceeded its charter authority in enacting the ordinance. View "Mo. Bankers Ass’n, Inc. v. St. Louis County, Mo." 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