Justia Missouri Supreme Court Opinion Summaries

Articles Posted in Election Law
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Rochelle Gray appealed from the judgment of the trial court in favor of Sylvester Taylor on Gray's petition challenging the qualifications of Taylor to run for election in the Democratic Party primary for state representative in the 75th district. The trial court held that although Taylor did not reside within the boundaries of the new district, the Missouri Constitution required only that he have resided for one year in the county or any of the district from which the new district was created through reapportionment. The Supreme Court affirmed, holding that, in the context of reapportionment within one year of a general election, the Constitution requires that a candidate satisfies the one-year residency requirement by residing in the county or any district from which a portion was incorporated in the new district where the candidate seeks office, even if the candidate does not reside in that portion. View "Gray v. Taylor" on Justia Law

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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

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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

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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

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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

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Molly Teichman, as a citizen and qualified voter, filed a petition for permanent writs of prohibition and mandamus to prevent the secretary of state from holding an election based on either the original or revised Senate plan and map submitted by the nonpartisan senate reapportionment commission. The Supreme Court sustained the petition and directed that a writ of prohibition issue to the secretary of state, holding (1) the commission had no authority to revise the reapportionment process on its own volition even if a majority of the members of the commission recognized a constitutional infirmity in the plan and map that had been unanimously signed and filed; (2) the original plan and map violated a clear and express constitutional limitation regarding the splitting of counties and was, therefore, invalid; and (3) Mo. Const. art. III, 7 compelled the legislative process to be redone in accordance with its terms. Remanded. View "State ex rel. Teichman v. Carnahan" on Justia Law

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Six state citizens and qualified voters residing in various areas of the state brought an action against the attorney general and secretary of state. A second group of citizens and qualified voters filed an action against the secretary of state, seeking declaratory and injunctive relief. Both sets of plaintiffs alleged that a redistricting map and configuration of certain districts were not valid under Mo. Const. art. III, 45. Defendants filed a motion to dismiss for failure to state a claim or, in the alternative, a motion for judgment on the pleadings. The circuit court granted both motions and dismissed both cases. The Supreme Court reversed the judgments, holding that the pleadings raised issues of fact concerning whether various districts were "composed of contiguous terrority as compact...as may be" under Mo. Const. art. III, 45, and therefore, the motions to dismiss could not be sustained because the facts alleged met the elements of a recognized cause of action. Remanded. View "Pearson v. Koster" on Justia Law