Justia Missouri Supreme Court Opinion Summaries

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

Herschel Young was sworn in as presiding commissioner of Cass County in 2011. Teresa Hensley, the prosecuting attorney for the county, subsequently filed a quo warranto action in reliance upon Mo. Rev. Stat. 115.350, alleging that Young usurped the office of presiding commissioner because he was not qualified to be a candidate for elective public office due to a 1995 felony conviction. The circuit court granted Hensley's petition and ordered Young's ouster from office. The Supreme Court affirmed, holding (1) section 115.350, as applied to Young, did not operate retrospectively in violation of the state constitution; (2) quo warranto was the appropriate remedy, and the petition was based on applicable law; and (3) section 115.350 does not violate the equal protection clause of the state constitution because it had a rational basis under the law. View "State ex inf. Hensley v. Young" on Justia Law

Jordan Danielle King-Willmann filed a petition seeking a writ of mandamus requiring the Webster Groves school district to enroll her in the district pursuant to Mo. Rev. Stat. 167.131.2. The school district contested certain material facts alleged by King-Willmann and asserted several defenses, including a claimed violation of Mo. Const. art. X, sec. 21, the Hancock amendment. The school district requested an evidentiary hearing, which the trial court did not hold. The court issued the writ granting King-Willmann relief. The Supreme Court reversed the judgment and remanded because contested issues of fact existed. On remand, the Court instructed the trial court not to consider the Hancock amendment claim as the school district had no standing to bring such a claim. View "King-Willmann v. Webster Groves Sch. Dist." on Justia Law

In 2007, the General Assembly enacted a series of statutes regulating the private investigator profession. Appellant subsequently applied for licensure as a private investigator. The Board of Private Investigator Examiners initially denied Appellant's application, but later the Administrative Hearing Commission ordered the board to grant Appellant a license. After Appellant was awarded a license, he continued to pursue a lawsuit he had filed against the board and its members, arguing that the statutory scheme violated the free speech clauses of the state and federal constitutions and that his procedural due process rights were violated when the board denied his application before giving him a meaningful opportunity to be heard. The circuit court (1) dismissed Appellant's procedural due process claim as moot, and (2) dismissed Appellant's free-speech claims after concluding that the statutes were not unconstitutional on their face. The Supreme Court affirmed, holding that the circuit court did not err in its judgment. View "Gurley v. Mo. Bd. of Private Investigator Exam'rs" on Justia Law

After My Truong's home was foreclosed on, a trustee's sale was held, and Fannie Mae purchased Truong's home. Despite the sale, Truong continued to maintain possession of his home. Fannie Mae filed a petition for unlawful detainer. The circuit court granted Fannie Mae's motion for summary judgment and awarded Fannie Mae $6,000 in damages. Truong appealed, challenging the constitutional validity of Mo. Rev. Stat. 534.010, among other things. The Supreme Court dismissed the appeal for lack of appellate jurisdiction, holding that Truong's failure to apply for a trial de novo pursuant to Mo. Rev. Stat. 512.180.1, prior to seeking relief in the Supreme Court, deprived the Court of the authority to adjudicate his claims. View "Fannie Mae v. Truong" on Justia Law

Respondents, Legends Bank and John Klebba, filed a declaratory judgment action asserting that S.B. 844 (the Bill), which the Legislature passed in 2010, (1) violated the single subject requirement and original purpose requirement of the Missouri Constitution, and (2) violated the First Amendment insofar as it barred political action committees from receiving money from state chartered banks but allowed political action committees to receive money from other entities and individuals. The trial court sustained Respondents' motion for judgment on the pleadings, finding (1) procurement was the original controlling purpose of the Bill, (2) the Bill was enacted in violation of the single subject requirement of the state Constitution, and (3) the Bill violated the First Amendment. The court then voided S.B. 844 except for the procurement provisions. The Supreme Court affirmed, holding that the Bill violated Mo. Const. art III, 21, which prohibits changes in the original purpose of a bill, as (1) the original purpose of the Bill related to procurement, and (2) the vast majority of the provisions in the final version related to ethics and campaign finance, which were not germane to the original purpose of the Bill. View "Legends Bank v. State" on Justia Law