Justia Missouri Supreme Court Opinion Summaries

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

Jesse Dorris, Jose Lopez-McCurdy and Louis Hill were denied the right to appeal their post-conviction relief motions on the merits because they were filed out of time. The State did not raise the issue of timeliness below. The Supreme Court (1) held that, pursuant to Mo. Sup. Ct. R. 29.15 and 24.035 (the Rules), the motion court had no authority to hear the motions, regardless of the State's failure to raise the issue, because the motions were filed out of time; (2) affirmed the dismissal of Dorris' and Lopez-McCurdy's cases because they were filed outside the mandatory time limits provided in the Rules and resulted in Dorris and Lopez-McCurdy completely waiving their post-conviction relief claims; and (3) remanded Hill's case for a hearing on the timeliness of his motion. View "Dorris v. State" on Justia Law

Custom Hardware Engineering (CHE) appealed an Administrative Hearing Commission (AHC) decision determining that CHE was liable for use tax plus interest and additions to tax on its purchases of parts for use in fulfilling maintenance contracts. CHE asserted that is was not liable for any use tax because it did not use the parts and, instead, retained them for "temporary storage" as provided in Mo. Rev. Stat. 144.605(13). The Supreme Court affirmed the AHC decision, holding (1) the record demonstrated that CHE used the parts for testing and certification on behalf of its customers; and (2) therefore, CHE was liable for use tax as provided in Mo. Rev. Stat. 144.610. View "Custom Hardware Eng'g & Consulting, Inc. v. Dir. of Rev." on Justia Law

CACH, LLC, a debt collector, brought an action against Jon Askew for an alleged outstanding debt owed by Askew. The circuit court entered judgment in favor of CACH and against Askew. Askew appealed, contending that CACH did not properly demonstrate that it had been assigned the debt in question and that the circuit court improperly admitted an exhibit based on the business records exception to the hearsay rule. The Supreme Court reversed, holding (1) the disputed exhibit was erroneously admitted into evidence by the circuit court under the business records exception; (2) without admission of the exhibit into evidence, CACH failed to provide any competent evidence of the alleged assignment of Askew's account to CACH; and (3) without evidence of the validity of this assignment, CACH did not demonstrate it had standing to pursue the claim. View "CACH, LLC v. Askew" on Justia Law

After a jury trial, Ines Letica was found guilty of first degree assault and armed criminal action. During voir dire, defense counsel used peremptory challenges to strike four Caucasion females from the panel, to which the State raised a reverse-Batson objection, alleging that a certain venireperson was struck with the peremptory challenge on the basis of gender, race or ethnic origin. The circuit court sustained the objection as to the venireperson. The Supreme Court affirmed the circuit court's judgment, holding (1) the circuit court erred when it ruled prematurely on the reverse-Batson challenge and did not require the State to demonstrate that racial or gender discrimination was the motivating factor for the peremptory strike, but the error was harmless under the facts in this case; (2) the evidence was sufficient to sustain the verdict; (3) Letica's sentences did not constitute plain error; (4) there was no prosecutorial misconduct in this case; and (5) the admission into evidence of certain photographs did not constitute manifest injustice or miscarriage of justice. View "State v. Letica" on Justia Law

Michael Patton filed a two-count personal injury action under the Federal Employers' Liability Act against his employer, BNSF Railway Company, alleging that BNSF negligently required him to perform heavy manual labor in extreme heat and, as a result, he lost consciousness and fell, and that striking his head in the fall caused him to suffer subsequent reoccurring seizures and fainting spells. To bolster its defense that Patton's injuries were caused by prescription drug use, BNSF sought discovery of records held by Patton's treating psychiatrist. The trial court issued a protective order preventing the discovery of the records. The Supreme Court granted a writ of mandamus ordering the trial court to lift its protective order, holding (1) the trial court abused its discretion in holding that discovery of the records of a treating psychiatrist is precluded entirely where, as here, the plaintiff alleges only physical rather than psychological injury; and (2) BNSF showed that it had reason to believe that discovery of treatment records held by Patton's psychiatrist was calculated to lead to the discovery of admissible evidence on its theory of causation. Remanded. View "State ex rel. BNSF Ry. Co. v. Judge Neill " on Justia Law

Missouri law provides for two sales tax rates: a standard rate of four percent that applies to most retail sales, and a reduced rate of one percent that applies to some, but not all, sales of food. Krispy Kreme sought review of a decision of the Administrative Hearing Commission (AHC) that Krispy Kreme must collect tax at the four percent rate on all retail food sales at its Missouri locations. At issue on appeal was whether Krispy Kreme's product fell under the definition of "food" in Mo. Rev. Stat. 144.014.1, which establishes the lower sales tax rate for purchases of food. The Supreme Court reversed in part and affirmed in part, holding (1) the phrase "food prepared by such establishment for immediate consumption on and off the premises" in section 144.014.1 means all food that is eaten at the place of preparation and purchase, or while traveling to, or immediately upon arrival at another location without any further preparation; (2) affirmed the AHC's decision to overrule Krispy Kreme's motion for summary decision because neither party was entitled to summary decision; and (3) reversed the portion of the AHC's decision sustaining the director's motion. Remanded. View "Krispy Kreme Doughnut Corp. v. Dir. of Revenue" on Justia Law

JLB Corporation, a mortgage brokering service, entered into an agreement with Bonnie Hargis to refinance her home. JLB then prepared Hargis's loan application and other financial disclosure documents. JLB alleged it played no role in drawing the note or deed of trust, which were prepared by third parties, and it did not charge for their preparation. Hargis, however, filed a three-count petition against JLB, alleging, inter alia, that JLB engaged in the unauthorized practice of law. The trial court granted summary judgment in favor of JLB on all counts. The Supreme Court (1) affirmed the grant of summary judgment to JLB as to the first two counts relating to the unauthorized practice of law where the record showed that JLB assisted Hargis only in preparing financial documents and did not show that JLB procured or assisted in the drawing of Hargis' note, deed of trust, or other legal documents; and (2) reversed the grant of summary judgment to JLB on the third count alleging unjust enrichment, as JLB's summary judgment motion failed to negate any element of Hargis' unjust enrichment claim. Remanded. View "Hargis v. JLB Corp." on Justia Law

This case involved four appeals that were consolidated because each involved the issue of whether evidence obtained in a search of a motor vehicle incident to a traffic arrest was admissible. In each case, there was no reason to believe that evidence of the crime for which each Defendant was arrested was in any of their vehicles. The searches were performed in compliance with binding appellate precedent, but while these cases were pending, Arizona v. Gant was decided, holding that such searches were unlawful. Each defendant, relying on Gant, filed a motion to suppress the evidence obtained from the searches. At issue before the Supreme Court was whether the exclusionary rule suppresses evidence obtained in a search conducted in compliance with binding precedent when such precedent was later overturned. The Supreme Court held (1) in accord with Davis v. U.S., the exclusionary rule did not apply because the searching officers acted in objectively reasonable reliance on settled, binding appellate precedent; and (2) the trial court's judgments sustaining the motions to suppress in three cases were reversed and remanded, and the trial court's judgment in the remaining case overruling the defendant's motion to suppress was affirmed. View "State v. Johnson" on Justia Law

Defendant was convicted by a jury of felonious restraint, deviate sexual assault, and first-degree sexual misconduct. Prior to sentencing, Defendant entered into an agreement with the State in which Defendant would plead guilty to two additional criminal counts and waive his rights to a jury trial, to direct appeal, and to seek post-conviction relief. In exchange, the State recommended that Defendant be sentenced to a combined total of fifteen years incarceration on all counts. The circuit court rendered and judgment and sentence in accord with the agreement. Defendant subsequently filed an amended motion for post-conviction relief, alleging ineffective assistance of counsel for, inter alia, incorrectly advising Defendant to waive his rights to a direct appeal. The motion court denied the motion. The Supreme Court vacated the motion court's judgment, holding that Defendant knowingly, voluntarily, and intelligently agreed to waive his post-conviction rights after his trial. Remanded with instructions to dismiss Defendant's post-conviction motion. View "Krupp v. State" on Justia Law