Justia Missouri Supreme Court Opinion Summaries

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

Two police officers were patrolling a high-crime area when they passed Defendant, who was riding a bicycle, and observed what appeared to be a handgun protruding from Defendant’s waistband. The officers handcuffed Defendant and then discovered that what appeared to be a gun was an Airsoft toy gun. At that point, the officers called in a warrant check and learned there was a pickup order for Defendant. A subsequent search revealed Defendant was carrying cocaine base. Defendant was charged with one count of possession of a controlled substance. Defendant filed a motion to suppress the evidence, which the trial court overruled. Defendant appealed, arguing that, although the police had reasonable suspicion to initially stop him when they saw him carrying what appeared to be a gun, they lacked reasonable suspicion to detain him further while they performed a warrant check after they discovered the gun was a toy gun. The Supreme Court affirmed, holding that the trial court did not clearly err in overruling Defendant’s motion to suppress because even after the officers learned the gun was not real, the additional circumstances surrounding the encounter gave them reasonable suspicion to continue to detain Defendant. View "State v. Lovelady" on Justia Law

After five jury trials, Appellant was eventually convicted of the 1991 murder of Gladys Kuehler and sentenced to death. The Supreme Court affirmed the conviction and sentence. Appellant timely filed a motion for post-conviction relief, raising thirteen points on appeal. The circuit court made findings of fact and entered a judgment overruling Appellant’s motion. The Supreme Court affirmed, holding (1) Appellant’s trial counsel rendered constitutionally effective assistance; (2) Appellant’s due process rights recognized under Brady v. Maryland were not violated; and (3) Appellant’s claim that the delay between his sentencing and execution violated his due process rights lacked merit. View "Barton v. State" on Justia Law

Appellant was charged with fourteen offenses, including one count of forcible rape, one count of aggravated stalking, and five counts of violating a protective order. Appellant was convicted of all counts and sentenced to a fifty-year term of imprisonment for forcible rape under Mo. Rev. Stat. 566.030.2. The Supreme Court affirmed Appellant’s convictions and sentences, holding (1) Appellant’s sentence for forcible rape did not exceed the maximum sentence for that offense where section 566.030.2 authorizes a range of punishment from five years to life imprisonment; and (2) Appellant’s convictions for aggravated stalking and violating a protective did not violate double jeopardy. View "State v. Hardin" on Justia Law

After Appellant was convicted of felony driving while intoxicated (DWI), the director of revenue suspended Appellant’s driving privileges for a minimum of ten years. Appellant later filed a petition for limited driving privileges. The circuit court dismissed Appellant’s petition, determining that Appellant was statutorily ineligible for limited driving privileges pursuant to Mo. Rev. Stat. 302.309.3(6)(b) due to his felony conviction. Appellant appealed, asserting that section 302.309.3 violated the equal protection clause of the state and federal constitutions by allowing DWI court participants and graduates to obtain reinstatement of limited driving privileges while denying a similar opportunity to non-participants. The Supreme Court affirmed, holding that Appellant failed to establish that section 302.309.3 violated his right to equal protection. View "Amick v. Dir. of Revenue" on Justia Law

Plaintiffs in this action included St. Louis County, the county superintendent of police, the county sheriff, and a deputy sheriff. Plaintiffs filed a petition seeking a declaratory judgment that the deputy sheriff salary supplementation fund established by Mo. Rev. Stat. 57.278 was unconstitutional and improperly administered. The circuit court dismissed the case on the grounds that none of Plaintiffs had standing and that all claims were barred by sovereign immunity. The Supreme Court (1) reversed the judgment to the extent that it dismissed Count IV, in which Plaintiffs alleged that the rejection of their application to obtain a grant from the fund was arbitrary and an abuse of discretion, as, under the facts of this case, the superintendent had a legal interest in obtaining judicial review of whether he was a county sheriff who was eligible to file a grant application; and (2) affirmed the remainder of the judgment. Remanded. View "St. Louis County v. State" on Justia Law

Plaintiff, who was formerly employed by Hospital, brought an eight-count petition against Hospital and Doctor (collectively, Defendants) alleging violations of the Missouri Human Rights Act (the MHRA) and other common law claims related to the termination of her employment. The circuit court granted summary judgment in favor of Defendants on all claims. The Supreme Court (1) reversed the circuit court's judgment with respect to Plaintiff's MHRA claims and wrongful discharge claim, holding (i) the circuit court erred in dismissing Plaintiff's MHRA claims on the grounds that Plaintiff failed to satisfy the statutory prerequisites for filing a lawsuit under the MHRA, and (ii) because Plaintiff's amended petition sufficiently invoked the public policy exception to the at-will employment doctrine, the circuit court erred in sustaining summary judgment in Hospital's favor on Plaintiff's wrongful discharge claim; and (2) affirmed the circuit court's judgment as to all remaining counts. Remanded.View "Farrow v. St. Francis Med. Ctr. " on Justia Law

In 1992, Mo. Rev. Stat. 273.327 was enacted, requiring persons engaged in commercial animal care to obtain a license and exempted pounds and animal shelters from paying annual licensing and per-capita fees. In 2010, the General Assembly passed S.B. 795, which repealed and reenacted section 273.327. The reenacted version of section 273.327 eliminated animal shelters from the entities exempt from the payment of fees. In 2011, the General Assembly passed S.B. 161, which repealed and reenacted section 273.327 and cured any procedural defects in the passage of S.B. 795. The Humane Society subsequently filed a petition for declaratory judgment and injunctive relief, asserting that the amended version of section 273.327 was unconstitutional because S.B. 795 was amended during its passage to change its original purpose. The trial court granted summary judgment for the State, concluding that the Humane Society's cause of action was moot as a result of the General Assembly's repeal and reenactment of section 273.327 in S.B. 161. View "Humane Society of the United States v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder. After the jury was unable to agree on punishment, the trial court conducted an independent review of the facts pursuant to Mo. Rev. Stat. 565.030.4 and imposed the death sentence. The Supreme Court affirmed the conviction and sentence, holding (1) any errors in the preparation of the trial transcript did not impede adequate appellate review and were not prejudicial; (2) the trial court did not err in its evidentiary rulings or in its instructions to the jury; (3) section 565.030.4 is not unconstitutional; (4) the trial court did not commit plain error in failing to hold a hearing regarding alleged the improper influence of a certain juror during jury deliberations; and (5) the death sentence in this case was proportional to the strength of the evidence.View "State v. Shockley" on Justia Law