Justia Missouri Supreme Court Opinion Summaries

Plaintiffs filed suit against West County Motor Company for violation of the Missouri Merchandising Practices Act (MMPA) and for conversion. Each plaintiff paid a deposit to West County to secure the purchase of a vehicle and signed a vehicle buyer's order providing that "all deposits are non refundable." However, all plaintiffs but one alleged that West County told them their deposits were refundable if the purchase was not completed. When Plaintiffs decided not to purchase their vehicles, West County told them their deposits would not be refunded. The trial court dismissed the MMPA claims for failure to state a claim. The Supreme Court (1) affirmed the trial court's dismissal of that portion of Plaintiffs' claims alleging violations of the MMPA based on violations of Mo. Rev. Stat. 364.070.4; and (2) reversed the trial court's dismissal of Plaintiffs' claims alleging violations of the MMPA based on conversion, lack of good faith, and an illegal liquidated damages clause, as Plaintiffs' allegations of conversion, unlawful liquidated damages, and lack of good faith were sufficient to survive a motion to dismiss. View "Ward v. W. County Motor Co., Inc." on Justia Law

Appellants lost their home in a foreclosure sale. When Appellants failed to vacate the home, Wells Fargo Bank, the foreclosure purchaser, sued for unlawful detainer. Appellants raised equitable defenses and counterclaims concerning the validity of Wells Fargo's title. Wells Fargo successfully moved to dismiss the defenses and counterclaims on the ground that they exceeded the statutory scope of issues that may be litigated in an unlawful detainer action under Mo. Rev. Stat. 534.210. The circuit court then granted summary judgment to Wells Fargo. Appellants appealed, arguing that section 534.210, which prohibits a defendant from raising equitable defenses and/or challenges to the validity of the plaintiff's title in an unlawful detainer action, was unconstitutional. The Supreme Court affirmed, holding (1) statutory limitations on the scope of unlawful detainer actions are not unconstitutional; and (2) Appellants failed to raise a genuine issue of fact concerning Wells Fargo's right to possession. View "Wells Fargo Bank, N.A. v. Smith" on Justia Law

A construction crane owned and operated by a construction company (Jacobsmeyer) fell on a building. Jacobsmeyer's insurer (Travelers) reached a settlement agreement with the designer and manufacturer of the crane (Grove) wherein Grove agreed to pay Jacobsmeyer and Travelers (hereinafter referred to collectively as Jacobsmeyer) for a majority of their remaining losses associated with the accident. Jacobsmeyer subsequently sued Grove and its parent company (hereinafter referred to jointly as Manitowoc) for breach of the settlement agreement. Manitowoc filed third-party petition claims for contribution and/or indemnity against U.S. Steel, alleging that U.S. Steel's predecessor-in-interest provided the faulty steel for the crane. The trial court dismissed Manitowoc's third-party petition with prejudice because Manitowoc failed to satisfy pleading requirements where it did not admit its own liability as a joint tortfeasor in its third-party petition. The Supreme Court reversed, holding that a party seeking contribution or indemnity need not admit its own fault in its third-party petition but rather can deny liability in its answer to the plaintiff's petition and assert in its third-party petition that if it is liable to the plaintiff, then the third-party defendant is liable to it. Remanded. View "Travelers Prop. Cas. Co. of Am. v. Manitowoc Co., Inc." on Justia Law

Whelan Security Company appealed a trial court's grant of summary judgment in favor of Charles Kennebrew and W. Landon Morgan on its action to enforce the non-compete agreements it had with Kennebrew and Morgan. On appeal, Whelan claimed that the trial court erred in concluding that the non-competition and non-solicitation clauses were invalid as overbroad and unreasonable as to time and space. The Supreme Court granted transfer and reversed, holding that the non-compete agreements were unreasonable as written but modified the terms of the agreements to give effect to the intent of the parties in entering the non-compete agreement; and (2) because genuine factual issues existed, entry of summary judgment was improper. Remanded. View "Whelan Security Co. v. Kennebrew" on Justia Law

Ruth Mendenhall appealed a summary judgment in favor of Property and Casualty Insurance Company of Hartford on her equitable garnishment claim seeking insurance coverage for the death of her husband, Len Mendenhall. The trial court's judgment was premised on the conclusion that Len was an "employee" under the terms of the Hartford policy and, therefore, was excluded from coverage. The Supreme Court reversed the judgment of the trial court, holding that, given the facts of this case and the policy language, Len was not an "employee" but was instead a "temporary worker" subject to coverage under the terms of the Hartford policy. View "Mendenhall v. Prop. & Cas. Ins. Co. of Hartford" on Justia Law

Appellant and Respondents entered into a lease agreement for a residence to be used by one of Respondents. Appellant later filed a petition for breach of contract and property damage against Respondents, claiming they had breached the terms of the lease and had committed waste on the property. Respondents filed a counterclaim against Appellant. The trial court ruled in favor of Respondents on Appellant's petition and in favor of Appellant on Respondents' counterclaim. The Supreme Court affirmed, holding, among other things, that there was substantial evidence supporting the trial court's determination that Respondents did not breach the lease agreement. View "Kieffer v. Icaza" on Justia Law

In 2008, St. Louis County (County) assumed control of solid waste collection in County's unincorporated areas. Prior to that, waste collection services had been provided by private entities, including respondent Haulers. Following a 2007 amendment to Mo. Rev. Stat. to 260.247, which extended hauler-protective business regulations to counties that wish to provide trash collection, Haulers sued County for a declaratory judgment that County must comply with section 260.247. Haulers also claimed they suffered money damages as a result of County's failure to comply with the statute. The circuit court found County liable to Haulers on the theory of implied in law contract and awarded Haulers $1.2 million in damages. The Supreme Court (1) reversed the circuit court's calculation of damages, holding that the circuit court was incorrect to exclude discovery or evidence of Haulers' expenses or net profit; and (2) affirmed the judgment in all other respects. Remanded. View "Am. Eagle Waste Indus. v. St. Louis County" on Justia Law

This was an appeal from the circuit court's entry of summary judgment quieting title to certain property in favor of Edward and Nancy Bosch. Harpagon MO, LLC asserted that the circuit court should have entered summary judgment in its favor because it complied with the requirements of Mo. Rev. Stat. 140.405 by providing the Bosches with timely and sufficient notice of their right to redemption. The Supreme Court affirmed, holding (1) a purchaser is authorized to acquire a deed to property purchased at a tax sale one year after the sale; (2) therefore, a purchaser must notify the owner of that property of the owner's right to redeem at least ninety days prior to one year after the tax sale; (3) if the purchaser does not provide timely or sufficient notice, but still acquires the deed by presenting the certificate of purchase to the collector, then the owner can file a petition to set aside the tax sale asserting the purchaser's failure to comply with section 140.405; and (4) the circuit court did not err in finding that the notices provided to the Bosches were not timely and thus awarding the Bosches quiet title to the property. View "Harpagon MO, LLC v. Bosch" on Justia Law

Missouri Title Loans appealed from a judgment finding that a class arbitration waiver contained in its loan agreement, promissory note, and security agreement (agreement) was unenforceable. The Supreme Court affirmed the judgment insofar as it held that the arbitration waiver was unconscionable and reversed that part of the judgment ordering that the claim be submitted to an arbitrator to determine suitability for class arbitration, holding that the appropriate remedy was to strike the entire arbitration agreement. The U.S. Supreme Court vacated the Court's judgment and remanded for further consideration in light of AT&T Mobility, LLC. v. Concepcion. Applying Concepcion, the Supreme Court affirmed in part and reversed in part, holding (1) the presence and enforcement of the class arbitration waiver did not make the arbitration clause unconscionable; (2) the formation of the agreement was unconscionable; and (3) therefore, the appropriate remedy was revocation of the arbitration clause contained within the agreement. Remanded. View "Brewer v. Mo. Title Loans, Inc." on Justia Law

Max and Glenna Overbey recovered judgments against Chad Franklin National Auto Sales North, LLC (National) and Chad Franklin (Franklin) for fraudulent representations in violation of the Missouri Merchandising Practices Act made in connection with National's sale of a vehicle to the Overbeys. Franklin appealed, and the Overbeys appealed the trial court's reduction of the punitive damage verdict as required by statute. The Supreme Court affirmed, holding (1) the award against Franklin was fully supported by the evidence; and (2) the limit of punitive damages did not violate the Overbeys' constitutional rights or the separation of powers doctrine. View "Estate of Overbey v. Chad Franklin Nat'l Auto Sales N., LLC" on Justia Law