Justia Missouri Supreme Court Opinion Summaries

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

Kevin Bromwell and several other inmates (Appellants) of the Jefferson County Correctional Center filed a petition for declaratory judgment and injunctive relief, alleging that the circuit court's application of the Missouri Prisoner Litigation Reform Act to petitions for writs of habeas corpus violated the state and federal Constitutions. Appellants then filed a consolidated petition for writs of habeas corpus. The circuit court quashed service of process, dismissed the counts alleged in the consolidated petition for declaratory judgment for failure to state a claim upon which relief may be granted, and dismissed the petition for writs of habeas corpus without prejudice. The Supreme Court affirmed the circuit court's judgment, holding (1) the consolidated petitions for writs of habeas corpus claims were properly dismissed and there was no right to appeal; and (2) the circuit court properly dismissed Appellant's declaratory judgment petition, as Appellants failed to state claims upon which relief could be granted. View "Bromwell v. Nixon" on Justia Law

Defendant Tyler McNeely refused to consent to an alcohol breath test or a blood test after he was arrested for driving while intoxicated. The arresting patrolman, without seeking a warrant from a judge, ordered a medical professional to draw Defendant's blood. The trial court sustained Defendant's motion to suppress the results of the blood test, concluding that the nonconsensual and warrantless blood draw was a violation of Defendant's Fourth Amendment rights. The Supreme Court affirmed, holding (1) the fact that blood-alcohol levels dissipate after drinking ceases is not a per se exigency pursuant to Schmerber v. California justifying an officer to order a blood test without obtaining a warrant from a neutral judge; and (2) the arresting patrolman, therefore, was not justified in failing to seek a warrant before drawing Defendant's blood over his refusal to consent. View "State v. McNeely" on Justia Law