Justia Missouri Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court overruling Defendant's Rule 29.15 motion for postconviction relief without holding an evidentiary hearing, holding that the circuit court did not clearly err in determining that Defendant failed to plead facts not refuted by the record that, if true, resulted in prejudice entitling him to an evidentiary hearing.Defendant was found guilty of four felony sexual offenses. The court of appeals. Defendant subsequently filed a Rule 29.15 motion to vacate, set aside, or correct the judgment, alleging several instances of ineffective assistance of counsel. The circuit court overruled the motion without conducting an evidentiary hearing. The Supreme Court affirmed, holding that the circuit court did not clearly err in denying Defendant's postconviction claims without an evidentiary hearing. View "McLemore v. State" on Justia Law

The Supreme Court reversed the judgment of the circuit court convicting Defendant of two counts of statutory rape in the second degree, holding that the circuit court erred in permitting witness testimony via two-way live video, in violation of Defendant's right to confrontation under the United States and Missouri Constitutions.Defendant was charged in connections of sexual assault by I.S. At trial, the circuit court allowed the virtual testimony of Erik Hall, a crime laboratory employee who collected a buccal swab from Defendant and completed a DNA analysis and laboratory report. Defendant was found guilty of two count of statutory rape. On appeal, Defendant argued that Hall's two-way live video feed testimony violated his constitutional right to confrontation and due process. The Supreme Court reversed, holding that the circuit court erred in admitting Hall's two-way live video testimony, and the error was not harmless beyond a reasonable doubt. View "State v. Smith" on Justia Law

The Supreme Court vacated the judgment of the circuit court finding that Juvenile committed acts that would constituted first-degree statutory sodomy if committed by an adult, holding that the circuit court erroneously declared and applied the law in admitting two-way video testimony, in violation of Juvenile's right to confrontation.Prior to his adjudication hearing, Juvenile filed an objection to a virtual adjudication and request to appear in person, arguing that he had a constitutional and statutory right to face-to-face confrontation of witnesses against him. The objection was overruled, and the court held the hearing in a "hybrid" format that utilized videoconferencing technology due to the COVID-19 pandemic. After the hearing, the circuit court sustained the allegation of first-degree statutory sodomy beyond a reasonable doubt. The Supreme Court vacated the judgment, holding that the circuit court's general statements concerning COVID-19 did not satisfy the requisite standard for admitting two-way video testimony, in violation of Juvenile's confrontation rights. View "In re C.A.R.A." on Justia Law

The Supreme Court vacated the judgment of the circuit court finding that J.A.T. committed acts that would constitute first-degree assault and armed criminal action if committed by an adult, holding that requiring J.A.T. to attend the adjudication hearing via two-way live video violated his constitutional rights to due process and confrontation.While J.A.T. repeatedly asserted his right to be physically present at his adjudication hearing to defend himself, the circuit court required J.A.T. to attend his adjudication hearing via two-way video to limit the exposure of germs during the COVID-19 pandemic. The Supreme Court vacated the circuit court's judgment, holding (1) generalized concerns about the COVID-19 virus may not override a juvenile's due process right to be physically present for his juvenile adjudication hearing at which his guilt or innocence will be determined; and (2) the circuit court erred in requiring J.A.T.'s attendance and participation via two-way video, in violation of J.A.T.'s due process right to be physically present at his adjudication hearing. View "In re J.A.T." on Justia Law

The Supreme Court affirmed the order of the circuit court sustaining Defendant's motion to suppress a cell phone and electronic data stored on that cell phone, holding that the circuit court did not err in sustaining the motion to suppress.The circuit court concluded that the search warrant failed to describe with sufficient particularity the thing to be seized and was so facially deficient that the executing officers could not reasonably have presumed it to be valid. The Supreme Court affirmed, holding (1) the seizure of a cell phone at the sheriff's office was outside the scope of the warrant, so the evidence was not validly seized; and (2) the officer conducting the search did not have a good faith basis when he executed the search warrant at the sheriff's office, contrary to the clear directions of the search warrant to search a cell phone located at a particular address. View "State v. Bales" on Justia Law

The Supreme Court vacated the judgment of the circuit court granting summary judgment in favor of the Defendants and dismissing Plaintiffs' action seeking a declaratory judgment that Mo. Rev. Stat. 321.320 is an unconstitutional special law and that House Bill No. 1446 (HB 1446) violates the single-subject provision of the Missouri Constitution, holding that the circuit court erred.The City of De Soto and James Acres brought this action against the governor and the attorney general challenging section 321.320 and HB 1446. The De Soto Fire Protection District intervened as a defendant. The circuit court entered judgment for Defendants. The Supreme Court vacated the judgment below, holding that HB 1446 violates the prohibition against multiple subjects in Mo. Const. art. III, 23 and that the entire bill is invalid and may not be enforced. View "City of De Soto v. Parson" on Justia Law

The Supreme Court affirmed the circuit court's reduction of a damages award in favor of Appellant in a medical negligence case against University Physician Associates (UPA) and various physicians (collectively, the Physicians), holding that the circuit court did not err.Appellant filed this lawsuit alleging that the Physicians acted negligently in the Caesarean delivery of her child and in her postpartum care. The jury allocated 100 percent of fault to the Physicians and awarded $30,000 in past economic damages, $300,000 in past non-economic damages, and $700,000 in future non-economic damages. The circuit court concluded that Mo. Rev. Stat. 538.210.2(2)'s non-economic damages for catastrophic personal injury applied and reduced the non-economic damages award from $1 million to $748,828. The Supreme Court affirmed, holding (1) section 538.210's non-economic damage caps do not violate Mo. Const. art. I, 22(a); and (2) the Physicians' points on appeal lacked merit. View "Ordinola Velazquez v. University Physician Associates" on Justia Law

The Supreme Court affirmed in part and vacated in part the judgment of the circuit court rejecting Plaintiffs' claims challenging the refusal by the Department of Social Services (DSS) to provide MO HealthNet coverage, holding that the circuit court erred in declaring Mo. Const. art. IV, 36(c) constitutionally invalid.Plaintiffs, three Missourians eligible for MO HealthNet coverage under article IV, section 36(c), brought this action challenging the DSS's refusal to provide coverage on the grounds that the General Assembly failed to appropriate adequate funding. The circuit court rejected the claims, finding that the ballot initiative that enacted article IV, section 36(c) violated Mo. Const. art. III, 51, which prohibits initiatives from appropriating money without creating revenue to fund the initiative. The Supreme Court affirmed in part and vacated in part the circuit court's judgment, holding (1) article IV, section 36(c) does not appropriate money and does not remove the General Assembly's discretion in appropriating money to MO HealthNet; and (2) therefore, the circuit court erred in concluding that article IV, section 36(c) violates article III, section 51. View "Doyle v. Tidball" on Justia Law

The Supreme Court affirmed the judgment of the circuit court finding the challenged provisions of House Bill No. 1413 violated multiple provisions of the Missouri Constitution and permanently enjoining its operation and enforcement, holding that HB 1413 is void in its entirety.HB 1413, which was enacted in 2018, significantly altered many aspects of public labor relations in the state. The circuit court found (1) the exemption of public safety labor organizations in Mo. Rev. Stat. 105.503.2(1) violates public employees' right to bargain collectively through representatives of their own choosing, in violation of article I, section 29; and (2) the exemption of public safety labor organizations violated Mo. Const. art. I, 29. The Supreme Court affirmed, holding (1) the circuit court did not err in finding that the exemption of public safety labor organizations violates multiple provisions of the Missouri Constitution and in permanently enjoining Defendants from administering or enforcing any provision of HB 1413; and (2) the operation of the subject exemption forces the Court to declare HB 1413 void in its entirety rather than sever the offending provision. View "Missouri National Education Ass'n v. Missouri Department of Labor & Industrial Relations" on Justia Law

The Supreme Court vacated and remanded the judgment of the circuit court dismissing Appellants' lawsuit against the Missouri Sheriffs' Retirement System (MSRS), holding that the statute authorizing a $3 surcharge violates Mo. Const. art. I, 14.At issue was Mo. Rev. Stat. 57.955, which provides that a $3 surcharge shall be assessed and collected in all state civil actions and in all criminal cases including violation of criminal or traffic laws, including infractions. Appellants received speeding tickets and pled guilty and paid court costs. Unbeknownst to Appellants was that three dollars of the total costs was the surcharge authorized by section 57.955. Appellants, on behalf of a putative class, sued MSRS, alleging that the purchase violated article I, section 14 of the Missouri Constitution. The circuit court dismissed the case, concluding (1) Appellants failed to join the clerks responsible for assessing, collecting, and remitting the surcharge as necessary and indispensable parties; and (2) the statute was not unconstitutional. The Supreme Court reversed, holding (1) the municipal court clerks were not necessary and indispensable parties; and (2) section 57.955 is not "reasonably related to the expense of the administration of justice" and therefore violates article I, section 14 of the Missouri Constitution. View "Fowler v. Missouri Sheriffs' Retirement System" on Justia Law