Justia Missouri Supreme Court Opinion Summaries

After a jury trial, Vincent McFadden was found guilty of first-degree murder and armed criminal action. Consistent with the jury's recommendation, McFadden was sentenced to death. The Supreme Court affirmed, holding (1) the trial court did not err in limiting the testimony of a defense witness; (2) McFadden was not subjected to double jeopardy; (3) the trial court did not err in striking a venireperson for cause or in denying McFadden's Batson challenge as to a venireperson; (4) the trial court did not plainly err during the guilt phase of McFadden's trial in admitting certain testimony; (5) the trial court properly instructed the jury; (6) the State did not violate McFadden's due process rights during all phases of the trial; (7) the trial court did not improperly admit hearsay into evidence; and (8) the imposition of the death penalty met the statutory requirements. View "State v. McFadden" on Justia Law

David Liberty was convicted of one felony count of first-degree promoting child pornography and eight felony counts of first-degree possession of child pornography. Liberty alleged that the evidence the State presented to insufficient to convict him of the charges. The Supreme Court (1) affirmed Liberty's conviction for promoting child pornography and one of his convictions for possession of child pornography, as the evidence was sufficient to support the verdict; but (2) reversed the remaining convictions for possession of child pornography, holding that the imposition of eight separate sentences for one instance of possession violated Liberty's constitutional protections against double jeopardy, as Mo. Rev. Stat. 573.037 did not ambiguously permit separate prosecutions for each image a defendant simultaneously possessed. This holding, however, did not preclude the State from retrying Liberty on the reversed charges, as double jeopardy principles did not bar Liberty's retrial. Remanded. View "State v. Liberty" on Justia Law

Two groups of plaintiffs filed declaratory judgment actions to challenge the constitutional validity of the congressional redistricting map in H.B. 193, claiming that it failed to meet the constitutional requirements for compactness. The trial court ruled that Plaintiffs failed to prove the map violated Mo. Const. art III, 45 and entered judgments in favor of Defendants, the attorney general and secretary of state, as well as the intervenors, members of the General Assembly. The Supreme Court affirmed, holding (1) the trial court did not err in its interpretation of the constitutional compactness standard; and (2) Plaintiffs did not meet their burden of proving that the trial court's judgment was against the weight of the evidence. View "Pearson v. Koster" on Justia Law

Plaintiffs, Missouri citizens and voters, filed a declaratory judgment action against the State and secretary of state to challenge the constitutionality of the redistricting plan for the Missouri House of Representatives filed by the nonpartisan reapportionment commission. The trial court permitted three current members of the House of Representatives to intervene in the lawsuit. The court subsequently entered judgment in favor of Defendants, concluding (1) Plaintiff failed to prove that the plan did not meet the constitutional requirements for population, contiguity, and compactness; and (2) the nonpartisan reapportionment commission did not violate the "sunshine law." The court subsequently entered judgment in favor of Defendants. Plaintiffs appealed. The Supreme Court affirmed, holding (1) the trial court did not err in finding that Plaintiffs failed to prove the House reapportionment map was unconstitutional and in permitting intervention by the three House members; an (2) the trial court properly found that the nonpartisan reapportionment commission did not violate the sunshine law. Affirmed. View "Johnson v. State" on Justia Law

On November 7 2006, Courtney George was elected prosecuting attorney for Phelps County. George did not receive any salary increases during her term in office despite a report issued by the Missouri Citizens' Commission on Compensation for Elected Officials on December 1, 2006 increasing the salary for associate circuit judges in 2007 and 2008. In 2010, George filed a petition for a writ of mandamus against the elected members of the county commission and others (Respondents), requesting a preliminary order compelling Respondents to approve increased compensation rates and to issue her underpayment of her salary for the duration of her term in office. The circuit court issued a preliminary order in mandamus but later quashed the order. At issue on appeal was whether a midterm increase in compensation for a full-time prosecuting attorney violates the provision of the Missouri Constitution prohibiting the compensation of government officers from being increased during the term of office. The Supreme Court made permanent the preliminary writ of mandamus, holding that because the midterm increase in compensation in this case resulted from the application of a statutory formula for calculating compensation in place before George took office, the increase did not violate the Constitution. View "State ex rel. George v. Verkamp" on Justia Law

Jermane Clark was convicted of first degree murder and armed criminal action. The prosecution's case against Clark depended principally on the testimony of two witnesses. One of the witnesses, Maurice Payne, claimed to have been an eyewitness to the murder. Previously, Payne had pleaded guilty to unrelated charges before the same judge who presided over Clark's murder trial. Payne admitted that he subjectively hoped that his testimony against Clark would favorably affect his sentence even though Payne's decision to testimony in Clark's case was not motivated by a plea agreement in his own case. Clark's attorney was not permitted to question Payne concerning this potential bias. The Supreme Court reversed, holding that the circuit court abused its discretion by refusing Clark the opportunity to cross-examine Payne on whether he was biased, and there was a reasonable probability that the error affected the outcome of the trial. Remanded. View "State v. Clark" on Justia Law

The director of revenue for the State revoked James Hill's driving privileges for a period of ten years beginning October 2000. In June 2005, Hill was convicted of the misdemeanor of possession of drug paraphernalia. In April 2011, Hill filed a petition for reinstatement of his driving privileges. The director asserted that Hill's 2005 conviction precluded reinstatement because Me. Rev. Stat. 302.060.1(9) barred reinstatement for persons convicted within the previous ten years of an offense related to alcohol, controlled substances or drugs. The trial court reinstated Hill's driving privileges and held that section 302.060.1(9) was unconstitutionally vague. The Supreme Court versed, holding that section 302.060.1(9) was not unconstitutionally vague given the facts in this case. View "Hill v. Dir. of Revenue" on Justia Law

St. John's Mercy Health System challenged the validity of the Missouri Health Facilities Review Committee (MHFRC) rule that exempted new hospitals costing less than $1 million from the statutory requirement of obtaining a certificate of need. St. John's further sought to enjoin the MHFRC from applying the rule and granting Patients First Community Hospital an exemption from the certificate of need requirement. The trial court held that the case was not justiciable and dismissed the action without prejudice but proceeded to address the merits of St. John's claim, finding that the MHFRC had not exceeded its authority in promulgating the rule. The Supreme Court affirmed the judgment as modified, holding (1) the case was ripe for judicial review; and (2) the new hospital rule was valid, and the MHFRC was within its authority to promulgate the rule. View "Mercy Hosps. E. Cmtys. v. Mo. Health Facilities Review Comm." on Justia Law

After a jury trial Kenneth Baumruk was found guilty of the first degree murder of his wife and sentenced to death. Baumruk timely filed a pro se motion for postconviction relief. The motion court denied some of the claims without an evidentiary hearing and held an evidentiary hearing on the remaining claims. The court then issued a judgment overruling all claims put forth by the motion. The Supreme Court affirmed the motion court's judgment, holding that the motion court did not err by overruling Baumruk's claims that his competency hearing counsel, trial counsel, and appellate counsel were ineffective for numerous reasons. View "Baumruk v. State" on Justia Law

Defendant Michael Tisius was convicted of two counts of first-degree murder for killing two law enforcement officers and was sentenced to death. The Supreme Court affirmed the judgment of the circuit court, holding that the circuit court did err in (1) admitting the certified court record of the complaint for Defendant's conviction for possession of a prohibited item in the department of corrections; (2) overruling Defendant's objections to the State's cross-examination of his expert; (3) failing to intercede sua sponte at multiple times during the State's closing argument; (4) submitting verdict mechanics instructions or mitigating circumstances instructions; and (5) sentencing Defendant to death, as the imposition of the death penalty met the statutory requirements. View "State v. Tisius" on Justia Law