Justia Missouri Supreme Court Opinion Summaries

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 In 2010, the General Assembly passed S.B. 795, which repealed and reenacted section 273.327.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 In 2011, the General Assembly passed S.B. 161, which repealed and reenacted section 273.327 and cured any procedural defects in the passage of S.B. 795.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

After a jury trial, Defendant was convicted of involuntary manslaughter in the first degree and armed criminal action. Defendant subsequently filed a petition for a writ of habeas corpus, claiming that the trial court's practice of permitting qualified jurors to opt out of jury service by agreeing to perform community service constituted a fundamental and systemic failure to comply with the statutory jury selection requirements. The circuit court and court of appeals denied the motion. Defendant then filed his writ petition with the Supreme Court. The Supreme Court denied the petition, holding that allowing five prospective jurors to opt out of service during Defendant's trial did not constitute a "substantial failure" to comply with the jury selection statutes or undermine the confidence in the verdict.View "State ex rel. Sitton v. Norman" on Justia Law

After a jury trial, Defendant was found guilty of twenty-six counts of first-degree murder, burglary, and related crimes for actions he took during a robbery and home invasion when he was sixteen years old. The trial court sentenced Defendant to life in prison with no possibility of parole for first-degree murder. The circuit court dismissed four counts on which the jury had found Defendant guilty, finding it had no jurisdiction over the charges because they were outside the scope of the juvenile court's certification. The Supreme Court held, inter alia, (1) the trial court erred in dismissing the four counts related to one of the victims of Defendant's crimes because she was not named in Defendant's juvenile petition; (2) the evidence at trial was sufficient to prove first-degree murder; and (3) Defendant's sentence of life without parole for first-degree murder violated the Eighth Amendment because it was imposed with no individualized consideration of the myriad of factors discussed in Miller v. Alabama. Remanded for resentencing. View "State v. Nathan" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder, first-degree robbery, and two counts of armed criminal action for shooting a killing a victim during the second of two robberies he committed when he was seventeen years old. The trial court sentenced Defendant to life in prison without the possibility of parole for murder. The Supreme Court affirmed, holding (1) the trial court did not reversibly err in playing Defendant's videotaped interrogation at trial; and (2) Defendant's sentence of life without parole violated the Eighth Amendment because it was imposed without any opportunity for the sentencing court to consider whether this punishment was appropriate in light of Defendant's age, maturity, and other factors discussed in Miller v. Alabama. Remanded.View "State v. Hart" on Justia Law

Driver was arrested for driving while intoxicated (DWI). The Director of Revenue (DOR) subsequently suspended Driver's license and disqualified him from driving a commercial motor vehicle. Driver filed a petition for a trial de novo in the trial court challenging the constitutional validity of Mo. Rev. Stat. 302.700 and 302.755, which disqualify drivers who are convicted of an alcohol-related traffic offense from driving a commercial vehicle for not less than one year. The trial court ruled that sections 302.500 and 302.700 violated the U.S. Constitution based on National Federation of Independent Business v. Sebelius (hereinafter NFIB) and reinstated Driver's driving privileges, including his commercial driver's license (CDL). The Supreme Court (1) reversed the trial court's judgment as to the constitutional validity of section 302.700 under NFIB, holding that NFIB was inapplicable to Driver's argument; and (2) denied Driver's due process and equal protection arguments, finding that they were without merit.View "Bone v. Dir. of Revenue" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to death. Defendant subsequently filed a motion for post-conviction relief. The motion court denied the motion after an evidentiary hearing on five of Defendant's fourteen allegations of error. The supreme Court affirmed, holding, among other things, that the motion court did not clearly err in (1) denying Defendant's claim that his trial counsel were ineffective for failing to investigate and present a diminished capacity defense; (2) failing to find the State committed a Brady violation; and (3) failing to find Defendant's trial counsel were ineffective for failing to object to the admission of a reenactment video without an evidentiary hearing.View "Johnson v. State" on Justia Law

The marriage of Husband and Wife was dissolved in 2003. In 2005 and 2006, the trial court reduced Husband's child support obligations and made no change to his maintenance obligation. While Husband's second appeal was pending, Wife filed a motion for attorney's fees on appeal. The trial court ordered Husband to pay $7,500 of Wife's attorney fees on appeal. The Supreme Court affirmed, holding (1) Mo. Rev. Stat. 452.355, which grants the circuit court subject matter jurisdiction to enter an award of attorney fees on appeal while the appeal is pending, is not unconstitutional; (2) section 452.355 is not unconstitutionally vague because it provides sufficient guidance so as to allow a person of ordinary intelligence to understand the standards to be applied by the circuit court in making an award of attorney fees; and (3) the trial court did not abuse its discretion in awarding Wife attorney's fees on appeal.View "Goins v. Goins" on Justia Law

Defendant pleaded guilty to two counts of failure to register as a sex offender pursuant to a plea agreement. After judgment was entered, Defendant filed a timely amended post-conviction motion seeking to vacate the judgment against him, contending that his plea counsel was ineffective and that the plea and sentencing court erred. Defendant’s post-conviction counsel subsequently withdrew from the case, and a second appointed lawyer filed a late second amended post-conviction motion. The circuit court overruled Defendant’s second amended motion without an evidentiary hearing, concluding that the record refuted Defendant’s claims. The Supreme Court affirmed, holding (1) the arguments raised in the late-filed second amended motion were time-barred; and (2) the motion court did not err in finding that Defendant was not entitled to a hearing on the claims raised in his first amended motion because the claims were refuted by the record. View "Stanley v. State" on Justia Law