Justia Missouri Supreme Court Opinion Summaries

The City of St. Peters enacted ordinance 4536 to authorize the use of an automated red light enforcement system. The ordinance creates an offense when a person fails to comply with the City Traffic Code and the violation is detected throughout the automated enforcement system. After a jury trial, Bonnie Roeder was found guilty of violating ordinance 4536. The trial court subsequently dismissed the charge against Roeder, concluding that the ordinance conflicted with state law by not assessing points against a violator’s driving record. The Supreme Court affirmed, holding that ordinance 4536 conflicts with Mo. Rev. Stat. 302.302.1, which requires the assessment of two points for a moving violation, because ordinance 4536 creates a moving violation and states that no points will be assessed. View "City of St. Peters v. Roeder" on Justia Law

The Missouri Municipal League (MML) filed this lawsuit challenging the validity of Mo. Rev. Stat. 302.341.2, as enacted in House Bill 103 (HB103), claiming that HB103 violated the bill-passage requirements in article III, sections 21 and 23 of the Missouri Constitution and that HB103 violated various substantive provisions of the constitution. The circuit court granted the State’s motion for judgment on the pleadings and entered judgment for the State. MML appealed. After this case was briefed, argued, and submitted, the General Assembly passed, and the Governor signed, Senate Bill 5 (SB5), which repealed the language in section 302.341.2 that formed the basis for MML’s claims. The Supreme Court dismissed MML’s appeal, as all of MML’s procedural and substantive claims had become moot. View "Miss. Municipal League v. State" on Justia Law

Employee filed a claim for workers’ compensation benefits arising out of a work-related pulmonary condition. Employer and Employee entered into a settlement that expressly left “future related pulmonary med[ical] care open.” An administrative law judge approved the settlement. The dispute in this case centered on Employer’s refusal to pay for certain inhaler medicines prescribed to Employee. Employee filed a request for a hearing before the Labor and Industrial Relations Commission to determine whether Employer was required to pay for the inhalers. The Commission concluded that it retained jurisdiction to determine Employer’s liability for Employee’s future medical care and ordered the parties to present their evidence in a hearing before the Division of Workers’ Compensation. Thereafter, Employer filed a petition for a writ of prohibition and, alternatively, mandamus, asserting that the parties’ settlement divested the Commission of jurisdiction over the issue of Employer’s liability for Employee’s future medical care. The Supreme Court quashed the preliminary writ, holding that the Commission was not divested of jurisdiction to determine the extent of a claimant’s entitlement to workers’ compensation benefits pursuant to a settlement that expressly leaves the issue of future medical care “open” and indeterminate. View "State ex rel. ISP Minerals, Inc. v. Labor & Indus. Relations Comm’n" on Justia Law

In 1993, Respondent pleaded guilty to one count of second-degree sex abuse, which required him to register as a sex offender. In 2012, Respondent filed a petition to be removed from Missouri’s sex offender registry and to be relieved from his obligation to register as a sex offender. The circuit court granted Respondent the relief he requested. The Missouri Attorney General subsequently filed a motion to intervene as a matter of right on behalf of itself, the State, and the Missouri State Highway Patrol (MSHP), seeking to set aside the circuit court’s order. The Supreme Court reversed, holding that the circuit court erred in overruling the Attorney General’s motion to intervene because (1) the Attorney General had the unconditional statutory right to intervene in Respondent’s action; and (2) the MSHP had an absolute right to intervene. Remanded. View "Dunivan v. State" on Justia Law

VisionStream, Inc., a Missouri corporation that designed and constructed trade show exhibits and displays, filed for a refund of Missouri sales taxes it remitted for its sale of trade show displays that it produced and shipped in Missouri for customer use outside of Missouri. The Director of Revenue denied the refund request. On appeal, the Administrative Hearing Commission (AHC) affirmed, determining that VisionStream was not entitled to a sales tax refund on purchases shipped out of state. In so doing, the AHC rejected VisionStream’s argument that title of the displays did not transfer to customers until delivery outside the state. The Supreme Court affirmed, holding that the evidence supported the AHC’s finding that title transferred in Missouri. Therefore, the transactions were subject to Missouri sales tax. View "VisionStream, Inc. v. Dir. of Revenue" on Justia Law

Liberty Energy (Midstates) Corp. (Liberty), a public utility and a gas corporation, requested an increase to its Infrastructure System Replacement Surcharge (ISRS). After an evidentiary hearing, the Missouri Public Service Commission (PSC) approved the ISRS increase for Liberty. Accordingly, Liberty filed new ISRS tariffs in compliance with the PSC’s order, and the PSC approved the tariffs. The Office of Public Counsel, which is appointed by the director of the department of economic development and may represent the public interest in appeals from the PSC’s orders, appealed. The Supreme Court reversed, holding that the PSC failed to follow the plain language of its statutory mandates, and therefore, its order was unlawful. Remanded. View "Missouri Pub. Serv. Comm’n v. Office of Pub. Counsel" on Justia Law

Geteway Taxi Management, d/b/a Laclede Cab Company (Laclede), operated a taxi service in the St. Louis metropolitan area. The Division of Employment Security determined that Laclede was liable for unemployment tax because its taxi drivers performed services for “wages” in the “employment” of Laclede. under Mo. Rev. Stat. 288.034.5. The appeals tribunal reversed. The Labor and Industrial Relations Commission (LIRC) reversed, finding that the taxi drivers were “employees” of Laclede under Mo. Rev. Stat. 288.034.5. The Supreme Court affirmed, holding that there was competent and substantial evidence on the record to support LIRC’s decision that Laclede’s drivers were employees of Laclede. View "Gateway Taxi Mgmt. v. Div. of Employment Sec." on Justia Law

Five Delta Alpha, LLC (FDA) purchased an aircraft and immediately leased it to JetSelect, LLC. After paying Missouri use tax under protest, FDA filed a use tax refund claim with the Director of Revenue, asserting that the purchase of the aircraft was eligible for exemption pursuant to Mo. Rev. Stat. 144.030.2(20) because the aircraft was leased to JetSelect as a common carrier providing air carrier service to the general public. The Director denied the claim. On appeal, the Administrative Hearing Commission (AHC) concluded that JetSelect was a common carrier but determined that FDA was not entitled to the refund because its lease was not a “sale” for purposes of the resale exemption. The Supreme Court reversed, holding that FDA showed clear and unequivocal proof that it qualified for the exemption because the lease to JetSelect constituted a sale for sales tax purposes. View "Five Delta Alpha, LLC v. Dir. of Revenue" on Justia Law

Custom Built, a personal training company, paid Powerhouse Gym of Joplin (Powerhouse), a fitness facility, rental fees covering the lease of office space and the opportunity to market and sell personal training services to Powerhouse members. The Department of Revenue (DOR) issued an assessment against Powerhouse for unpaid sales tax on the rental fees. Powerhouse challenged the assessment, and the Administrative Hearing Commission (AHC) determined that Powerhouse did not owe sales tax on the rental fees collected from Custom Built. DOR appealed, contending that the rental fees were subject to sales tax as a fee paid to a place of recreation under Mo. Rev. Stat. 144.020.1(2). The Supreme Court affirmed the AHC’s decision, holding that Powerhouse was not liable for sales tax on the monthly rental fees because Powerhouse did not render a taxable service to Custom Built. View "Tatson, LLC v. Dir. of Revenue" on Justia Law

In 2008, the General Assembly passed a senate bill that was codified as Mo. Rev. Stat. 393.1050, a statute exempting electric utilities that met a certain renewable energy target on a certain date from any solar energy requirements. A ballot initiative (“Proposition C”) was subsequently passed that imposed solar energy requirements on all electric utilities. Earth Island Institute, doing business as Renew Missouri, and additional parties filed a complaint with the Public Service Commission claiming that section 393.1050 was invalidated by the passage of Proposition C. The Commission determined that Proposition C did not impliedly repeal section 393.1050 because the two laws could be harmonized. The Supreme Court reversed, holding that section 393.1050 was impliedly repealed by the adoption of Proposition C because section 393.1050 in its entirety was in conflict with Proposition C. View "Earth Island Inst. v. Union Elec. Co." on Justia Law