Justia Missouri Supreme Court Opinion Summaries

Appellant, the same-sex partner of a highway patrolman who was killed in the line of duty, applied for survivor benefits under Mo. Rev. Stat. 104.140.3, which provides survivor benefits to the surviving spouse of a highway patrol employee who is killed in the line of duty. The Missouri Department of Transportation and Highway Patrol Employees' Retirement System denied Appellant's application. Appellant argued before the circuit court that the survivor benefits statute violated his equal protection rights by excluding him from survivor benefits because of his sexual orientation and violated the constitutional proscription against special laws. The circuit court affirmed the administrative decision. The Supreme Court affirmed, holding (1) Appellant was not eligible for survivor benefits because he was not married to the patrolman; and (2) the survivor benefits statute is constitutional and is not a special law. View "Glossip v. Mo. Dep't of Transp. & Highway Patrol Employees' Ret. Sys." on Justia Law

After the Missouri Governor allegedly withheld certain monies from the 2012 fiscal year state budget for the Legislature, the Supreme Court, and the Auditor's office, the state Auditor filed a declaratory judgment action challenging the Governor's authority under the Missouri Constitution to withhold those amounts. The trial court concluded (1) the Governor has discretion to control the rate of expenditures and to withhold or reduce expenditures at any time until the final day of the fiscal year; and (2) the Governor was authorized to increase appropriations based on an estimated, or "E" designation, on the line item. The Supreme Court dismissed the Auditor's claims, holding (1) the Auditor did not have standing to challenge the Governor's authority to withhold funds prior to the end of the fiscal year; (2) the Auditor did not have standing to challenge the "E" appropriations; and (3) the issue of the Governor's authority to withhold a portion of the Auditor's budget was not ripe for adjudication. View "Schweich v. Nixon" on Justia Law

In 2001, Respondent pleaded guilty to the class B felony of possession of a controlled substance with intent to distribute. In 2011, Respondent was indicted for knowingly and unlawfully possessing a .38 caliber revolver in violation of Mo. Rev. Stat. 571.070, which provides that a person commits unlawful possession of a firearm if he knowingly has a firearm in his possession and has been convicted of a felony. Respondent moved to quash or dismiss the indictment, arguing that section 571.070 violated the Missouri Constitution as applied to him because it was an ex post facto law. The circuit court entered judgment in favor of Respondent. The Supreme Court reversed, holding that section 471.070 was not an ex post facto law because it did not apply to conduct completed before its enactment. View "State v. Harris" on Justia Law

In 1994, Appellant pleaded guilty to sodomy. Congress subsequently passed the federal sex offender registration act (SORNA), which required individuals such as Appellant to register as sex offenders. Before SORNA was enacted, Appellant completed his involvement in the criminal justice system. Appellant filed a petition challenging SORNA's constitutional validity as applied to him. The circuit court entered summary judgment against Appellant. The Supreme Court affirmed, holding (1) SORNA does not violate the nondelegation doctrine; (2) the registration requirement does not violate Appellant's right to substantive due process nor the prohibition in the U.S. Constitution against ex post facto criminal laws; and (3) SORNA complies with principles of federalism. View "Roe v. Replogle" on Justia Law

St. Louis County appealed a judgment awarding property owners damages from the taking of their real properties by eminent domain. The County claimed the judgment should have been reversed because the trial record was inadequate for appellate review because portions were inaudible or not recorded. Further, the County claimed the trial court abused its discretion in its evidentiary rulings and that the verdict was excessive and unsupported by the evidence. Upon review, the Supreme Court found no error, and that the verdict was supported by sufficient evidence. Therefore, the Court affirmed the trial court's judgment. View "St. Louis County vs. River Bend Estates Homeowners' Association" on Justia Law

After a trial, Defendant was convicted of misdemeanor criminal nonsupport. Defendant appealed, contending that the trial court erred in overruling his motion for judgment of acquittal claiming Mo. Rev. Stat. 568.040 violated his due process rights because it forced him to disprove an element of the offense. Specifically, Defendant asserted that section 568.040 was unconstitutional because it makes lack of good cause an element of the crime of criminal support but then shifts the burden of proving good cause to the defendant. The Supreme Court affirmed the conviction, holding (1) the statute makes lack of good cause an element of the offense that the State must prove beyond a reasonable doubt; and (2) sufficient evidence supported the trial judge's conclusion that Defendant's failure to pay the ordered child support was without good cause. View "State v. Holmes" on Justia Law

After the St. Louis Public School District (SLPS) became unaccredited in 2007 and was operated by the Transitional School District of St. Louis, some parents sought to have their children obtain Mo. Rev. Stat. 167.131 transfers that would enable the children to attend school in the Clayton school district. The parents (Plaintiffs) also requested that the transitional school district pay for their children's education in Clayton. The trial court held in favor of the school districts (Defendants). The Supreme Court reversed, holding that section 167.131, the "Unaccredited District Tuition Statute," was applicable to the transitional school district and required that it pay Plaintiffs' children's tuition costs for attending Clayton. On remand, the trial court allowed taxpayers from Clayton and SLPS to intervene. The trial court found in favor of Defendants, holding that section 167.131 was unenforceable as applied to Defendants because (1) it violated the Hancock Amendment of the Missouri Constitution, and (2) Defendants' compliance with the statute was impossible. The Supreme Court reversed, holding (1) section 167.131, as applied to Defendants, did not violate the Hancock Amendment; and (2) the trial court erred in finding it would be impossible for Defendants to comply with the requirements of the statute. Remanded. View "Breitenfeld v. Sch. Dist. of Clayton" on Justia Law

A port authority sought to purchase a parcel of land owned by trustees of a family trust. After negotiations failed, the port authority filed a petition for condemnation of the parcel. The trustees argued that the sole purpose for the taking was economic development, in violation of Mo. Rev. Stat. 523.271, and that the taking was for private use, in violation of the Missouri Constitution. The circuit court ordered condemnation hearing, concluding (1) the taking did not violate section 523.271 because the taking would facilitate construction of a loop track and improve river commerce in addition to promoting economic development; and (2) the taking served the public purpose of promoting economic development. The trustees petitioned the Supreme Court for a writ of prohibition. The Supreme Court granted the writ because the circuit court failed to find any purpose for the taking that was not included in the legislature's definition of "economic development," and therefore, held that the proposed taking was in excess of the port authority's condemnation authority. View "State ex rel. Jackson v. Circuit Court" on Justia Law

Defendant pleaded guilty to first degree assault and armed criminal action (ACA). Defendant subsequently filed a motion for post-conviction relief pursuant to Mo. R. Crim. P. 24.035, alleging ineffective assistance of counsel. The circuit court dismissed the motion as untimely filed because Defendant filed it within 180 days of his delivery to the department of corrections for his first degree assault sentence, which triggered the period in which he could file a post-conviction relief motion challenging that conviction and sentence. The court of appeals affirmed, holding that the triggering event was Defendant's previous delivery to the department of corrections to serve his ACA sentence imposed in the same judgment. The Supreme Court affirmed, holding (1) the circuit court did not err in dismissing Defendant's motion as to his claim of ineffective assistance of plea counsel because the claim was not timely filed; and (2) Defendant's claim that his counsel at his probation revocation hearing on his assault conviction was ineffective was not cognizable in a Rule 24.035 proceeding. View "Swallow v. State" on Justia Law

Employee was terminated from her employment after her driver's license was suspended due to her epilepsy. Employee filed this action against Employer, alleging discrimination and retaliation in violation of the Missouri Human Rights Act (MHRA). The jury returned a verdict in favor of Employee in the amount of $11,250 for compensatory damages. Employee filed a motion for additur or, in the alternative, a new trial. The circuit court sustained Employee's motion and gave the parties thirty days to accept a higher amount of compensatory damages or elect a new trial on these damages only. Employer would not agree to an enhanced compensatory damage award, and the circuit court ordered a new trial on the basis that the verdict was against the weight of the evidence. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion in sustaining Employee's motion; and (2) the circuit court did not abuse its discretion in ordering a new trial on the issue of compensatory damages only. View "Badahman v. Catering St. Louis" on Justia Law