Justia Missouri Supreme Court Opinion Summaries

Defendant pleaded guilty to three counts of statutory sodomy in the first degree. Before trial, a third amended information was filed that charged Defendant as a predatory sex offender on Counts I and III. A factual basis of Defendant's guilt and status as a predatory sex offender was established at the plea hearing. Defendant filed a motion for post-conviction relief, alleging (1) his constitutional right to a jury trial was denied when the circuit court overruled his motion challenging the trial court's determination of his classification as a predatory sexual offender under Mo. Rev. Stat. 558.018, and (2) his due process rights were violated when the trial court overruled his motion challenging the hearing classifying him as a predatory sexual offender under Mo. Rev. Stat. 558.021.2 before the commencement of the scheduled jury trial. The motion court overruled Defendant's post-conviction motion without an evidentiary hearing. The Supreme Court affirmed, holding that the motion court did not clearly err in determining Defendant waived his constitutional challenges when he pleaded guilty. View "Garris v. State" on Justia Law

In 1983, Respondent pleaded guilty to one count of first-degree sexual assault. In 1995, Missouri's Sex Offender Registration Act (SORA) became effective, requiring Respondent to register as a sex offender. In 2010, Respondent filed a declaratory judgment action asserting that SORA violates Mo. Const. art I, 13 and that he was not required to register pursuant to the federal Sexual Offenders Registration and Notification Act (SORNA). The trial court (1) entered a declaratory judgment finding that, as applied to Respondent, SORA violated the bar against the enactment of retrospective state laws set forth in article I, section 13; and (2) declined to address the applicability of SORNA, therefore declining to order Defendants to remove Respondent's name from the registry and to destroy all registration records. The Supreme Court (1) reversed the judgment to the extent it held that the trial court was without authority to address the applicability of SORNA and that the SORA registration requirements violated article I, section 13 as applied to Respondent; and (2) affirmed the judgment to the extent that it did not order Defendants to destroy the registration records. View "Doe v. Toelke" on Justia Law

Defendant appealed the circuit court's judgment convicting him of five counts of possession of child pornography. Defendant asserted three points on appeal. The Supreme Court affirmed the judgment, holding (1) the trial court did not err in overruling Defendant's motion to suppress an affidavit offered in support of the search warrant used to seize the evidence because the affidavit established probable cause; (2) the entry of five separate convictions did not constitute double jeopardy or violate Defendant's rights to due process and trial by jury; and (3) the trial court properly admitted evidence of the content of resumes found on Defendant's computer. View "State v. Roggenbuck" on Justia Law

Appellant was convicted by a jury of first-degree murder, kidnapping, attempted forcible rape, and armed criminal action. The trial court sentenced Appellant to death and three life sentences to be served consecutively. After the Supreme Court affirmed his convictions, Appellant filed a motion for post-conviction relief, alleging several instances in which his trial counsel rendered ineffective assistance. The motion was overruled after an evidentiary hearing. The Supreme Court affirmed the judgment denying post-conviction relief, holding that the motion court did not clearly err in denying Appellant post-conviction relief, as Appellant's assertions of ineffective assistance of counsel were without merit. View "Johnson v. State" on Justia Law

Two cities separately appealed judgments entered against each city and in favor of the Eastern Missouri Coalition of Police, Fraternal Order of Police, Lodge 15 ordering the public employer to adopt collective bargaining procedures. In a consolidated opinion in the two cases, the Supreme Court held (1) the right to organize and bargain collectively recognized in the Missouri Constitution inherently imposes a duty on each city to bargain collectively with the exclusive bargaining representative elected by its police officers and sergeants with a goal of reaching an agreement; (2) the cities here were not excused from carrying out this duty because the public employees represented by the union were not covered by the procedures codified in the public sector labor law; but (3) nevertheless, because the cities may not be able to meet their duty without establishing a framework, the trial courts erred in ordering them to do so. Furthermore, the Court entered judgment ordering the cities to recognize the union as the collective bargaining unit for the cities' police officers and sergeants and to begin to meet and confer with the union for collective bargaining. View "E. Mo. Coal. of Police v. City of Chesterfield" on Justia Law

The American Federation of Teachers, its St. Louis affiliate, and individual representatives appealed the trial court's summary judgment declaring that the board of education of the Construction Career Center Charter School District and the individual members of the board had no duty to "meet and confer" or to bargain collectively in good faith with the union. The Supreme Court reversed, holding that because Mo. Const. art. I, 29 provides that all employees, public and private, have a right to organize and to bargain collectively, it necessarily requires the board to meet and confer with the union, in good faith, with the present intention to reach an agreement. Remanded. View "Am. Fed'n of Teachers v. Ledbetter" on Justia Law

The State appealed two judgments declaring Mo. Rev. Stat. 556.036 unconstitutional and dismissing, with prejudice, the criminal charges against Grant Mixon and Jeffrey Anderson. The judgments of the circuit court declared section 556.036 unconstitutional for conflicting with Mo. Const. art. I, 17, which prohibits felony prosecutions "otherwise than by indictment or information," because the circuit court determined the statute allowed for prosecution of a felony by complaint. The Supreme Court reversed, holding that Mixon and Anderson failed to demonstrate that section 556.036.5 "clearly and undoubtedly" violated Mo. Const. art. I, 17. Remanded. View "State v. Mixon" on Justia Law

The City of St. Louis appealed the trial court's holding that the prohibition against special laws contained in Mo. Const. art. III, 40 was not violated by Mo. Rev. Stat. 320.097. That statute exempted certain veteran firefighters who lived in areas with unaccredited or provisionally accredited school districts from any local laws requiring them to live in their home district. The State also appealed, alleging (1) the trial court erred in holding that section 320.097 violated what the trial court believed was the "broad measure of complete freedom from State legislative control" given to constitutional charter cities by the Missouri Constitution, and (2) the trial court erred in holding that the statute violated the equal protection clauses of the Missouri and U.S. constitutions because it was not rationally related to any legitimate purpose. The Supreme Court (1) affirmed the trial court's holding that the statue was not a special law in violation of the Missouri Constitution; (2) reversed the trial court's holding that the statute violated the state constitution because it interfered with the City's right to set its employees' and officers' powers, duties and compensation; and (3) reversed the trial court's holding that the statute violated equal protection guarantees. View "City of St. Louis v. State" on Justia Law

A jury found Appellant guilty of four counts of first-degree murder and armed criminal action for the shooting deaths of his girlfriend and her three children. Appellant was sentenced to death for his crimes. Appellant subsequently filed a motion for post-conviction relief, alleging ineffective assistance of counsel. After an evidentiary hearing regarding some of Appellant's claims, the motion court overruled his motion. The Supreme Court affirmed, holding that Appellant failed to make a sufficient showing to support Strickland v. Washington's prejudice prong because of the overwhelming evidence presented that established his guilt, and therefore, the motion court did not err in overruling the motion. View "Taylor v. State" on Justia Law

The State issued a warrant for Defendant's arrest after it was discovered that he was secretly videotaping clients while they undressed at his massage therapy business. Defendant was arrested and sought release on bail. Pursuant to Mo. R. Crim. P. 33.01, the circuit court set a $75,000 cash-only bond. Defendant sought relief of the court's order, arguing that the setting of a cash-only bond violates the requirement of Mo. Const. art. I, 20 that the bail shall be permitted by "sufficient sureties." After considering the purposes and the history of bail as well as the numerous understandings of the word "sufficient surety," the Supreme Court held that the trial court did not err in exercising its discretion to require a cash-only bond, as the imposition of a cash-only bail does not violate the Missouri Constitution. View "State v. Jackson" on Justia Law