Justia Missouri Supreme Court Opinion Summaries

Laclede Gas Company maintained gas lines along Pitman Hill Road in St. Charles County. Pitman Hill Road and the gas lines were located within areas established as public roads on five recorded subdivision plats. Each of the subdivision plats first established public roads and then designated the roads as utility easements. The plats specifically stated that one of the purposes of the utility easements was for the installation and maintenance of gas lines. The County planned to widen Pitman Hill Road, which required Laclede to relocate its gas lines. Laclede declined to pay for the relocation, after which the County filed a declaratory judgment action to require Laclede to bear the cost of relocation. The circuit court entered summary judgment in favor of the County. The Supreme Court reversed, holding that the County was required to reimburse Laclede for displacing the gas lines from Laclede's utility easement because the easements were constitutionally cognizable property interests and, therefore, requiring Laclede to relocate its gas lines without compensation would amount to an unconstitutional taking of private property. View "St. Charles County v. Laclede Gas Co." on Justia Law

William Foster was convicted of capital murder, first-degree robbery, and armed criminal action. Many years later, the department of corrections informed Foster that any funds deposited into his prison account to pay for college correspondence courses or an attorney would be subject to seizure by the state, pursuant to the Missouri Incarceration Reimbursement Act (MIRA). Foster filed a petition for declaratory judgment seeking a declaration that MIRA could not be applied to require reimbursement from him for the cost of his incarceration because the criminal acts that resulted in his incarceration were committed prior to the law's enactment. The trial court dismissed Foster's petition. The Supreme Court affirmed, holding that the facts alleged in Foster's petition were not developed sufficiently to give rise to a ripe controversy because the petition did not allege that Foster would receive sufficient assets to trigger the state's authority to seek reimbursement under MIRA. View "Foster v. State" on Justia Law

Kasim Faruqi was convicted for attempted enticement of a child. Faruqi appealed, arguing (1) the trial court erred in overruling his motion to dismiss the indictment because the statute setting forth the crime of enticement of a child was unconstitutionally vague, (2) the statements he made to a detective should have been suppressed as involuntary because they were procured by false statements that rose to the level of implied threats, and (3) the evidence discovered on his work computer should have been suppressed because it was discovered as a result of an unlawful search and seizure. The Supreme Court affirmed the judgment of the trial court, holding (1) Faruqi's vagueness challenge failed because the statute puts a person of ordinary intelligence on notice that, if he or she is at least twenty-one years old, attempting to entice a person younger than the age of fifteen years for the purpose of engaging in sexual conduct, regardless of whether the victim is, in fact, younger than fifteen years, is a crime; (2) Faruqi's statements were not obtained involuntarily; and (3) Faruqi's Fourth Amendment claim was barred as he maintained no subjective expectation of privacy in his work computer. View "State v. Faruqi" on Justia Law

After a jury trial, Reginald Griffin was found guilty of murder for the fatal stabbing of James Bausley and sentenced to life imprisonment without parole. Griffin filed a petition for a writ of habeas corpus, alleging that the State failed to disclose evidence that implicated another man as an alternate perpetrator and, hence, the State violated Brady v. Maryland. The circuit court denied the habeas petition. The Supreme Court granted the petition and held that Griffin met his burden of proving entitlement to habeas relief. Because Griffin showed that the nondisclosure of the evidence at issue was prejudicial for Brady purposes, he also established the prejudice necessary to overcome the procedural bar to granting him habeas relief. Accordingly, Griffin's conviction for the murder of Bausley was vacated. View "State ex rel. Griffin v. Denney" on Justia Law

Two taxpayers filed a petition for declaratory judgment challenging the constitutional validity of Mo. Rev. Stat. 99.1205, the Distressed Areas Land Assemblage Tax Credit Act. The taxpayers claimed that the tax credits provided by the Act constituted an unconstitutional grant or lending of public money to private persons, associations, or corporations. The trial court declined to enter declaratory judgment, concluding that the taxpayers did not have standing to challenge the statute. On appeal, the taxpayers argued they had standing because the tax credits were direct expenditures of funds generated through taxation and that the tax credits given under the Act were unconstitutional. The Supreme Court affirmed, concluding (1) the taxpayers did not meet their burden to prove they had standing to bring a challenge to the statute as the issuance of tax credits does not constitute a direct expenditure of funds generated through taxation, and (2) in accordance with Arizona Christian School Tuition Organization v. Winn, tax credits are not government expenditures and any effect on taxpayers in general is "merely speculative." View "Manzara v. State" on Justia Law

The underlying dispute in this case involved a contract and tort action brought by homeowners in a subdivision against certain homebuilders, including the Kerckhoff defendants. The trial court ordered that the case be referred to mediation. The parties were unable to agree to terms in a written settlement agreement at the conclusion of the mediation. The homeowners and some defendants then filed motions to enforce settlement and motions for sanctions against the Kerckhoffs, alleging the Kerckhoffs acted in bad faith during the mediation. The trial court entered an order denying the motions to enforce settlement but granted the motions for sanctions. The Kerckhoffs filed a motion with the trial court requesting that its order be certified as final and appealable, and the court entered an order finding that its prior ruling imposing sanctions was final for purposes of appeal. The court of appeals dismissed the appeal for lack of a final judgment. The Supreme Court granted transfer and dismissed the appeal, holding that because the trial court's order imposing sanctions did not dispose of a "claim for relief," the trial court certification of its order as final and appealable under Mo. R. Civ. P. 74.01 was ineffectual. View "Buemi v. Kerckhoff" on Justia Law

St. Louis County enacted an ordinance that established a new trash collection program in the county. Specifically, the ordinance authorized the county to establish trash collection areas in the county and allowed the county executive to advertise for bids or proposals to provide services for trash collection in the designated areas and award contracts to selected trash haulers. The County subsequently enacted an ordinance prohibiting trash haulers that were not selected in the bidding process from providing trash collection services within the eight designated collection areas. Taxpayers living in the waste collection areas then filed a class action petition, alleging (1) the County violated its charter and Mo. Rev. Stat. 260.247, violations that deemed the trash collection program void, and (2) the respondents violated the Missouri Merchandising Practices Act (MPA). The trial court granted the respondents' motion to dismiss for failure to state a claim. On appeal, the Supreme Court affirmed, holding (1) the County did not violate its charter, (2) the taxpayers did not have standing to file a claim under Section 260.247, and (3) the taxypayers' claim under the MPA was derivative of their claims that the trash collection program was void, so that claim also failed. View "Weber v. St. Louis County " on Justia Law

Catherine Stone was employed as a nurse at a nursing facility when she physically restrained a patient in an attempt to force-feed the patient medication. The Department of Health and Senior Services placed Stone on the employee disqualification list for eighteen months after finding that Stone knowingly abused a patient. Stone sought review of the Department's decision, arguing that (1) there was insufficient evidence to support the decision because expert testimony was required to prove that she knowingly abused a patient with dementia and mental disabilities, and (2) the Department deprived her of due process of law by allegedly failing to provide notice of her violations. The circuit court reversed the decision of the Department. The Department appealed, and after opinion by the court of appeals, the Supreme Court granted transfer. The Supreme Court reversed the judgment of the trial court, holding (1) the Department's lay witnesses' testimony was substantial and competent evidence that Stone knowingly abused a patient; (2) the Department provided her with notice of her violations, and therefore, Stone's due process rights were not violated; and (3) the decision of the Department was authorized by law and supported by substantial and competent evidence. View "Stone v. Mo. Dep't of Health & Senior Servs." on Justia Law

The Public Service Commission (PSC) approved Great Plain Energy's acquisition of Aquila, a Missouri utility company. Before approval was granted, Praxair, AG Processing, and Sedalia Industrial Energy Users' Association (collectively, Praxair) intervened. During evidentiary hearings, Great Plains, Aquila, and a subsidiary of Great Plains filed a motion to limit the scope of the proceedings, seeking to preclude any evidence as to their gift and gratuity policies. The regulatory law judge granted the motion, finding the evidence was wholly irrelevant to the merger. After the merger was approved, Praxair and the Office of Public Counsel filed petitions for writs of review. The circuit court affirmed the regulatory law judge's order. After opinion by the court of appeals, the Supreme Court granted transfer. The Court affirmed, holding (1) while the evidence as to Great Plains' gift policy should have been admitted, its exclusion was not prejudicial as the gift policy could not have substantially impacted the weight of the evidence evaluated to approve the merger; and (2) although certain PSC commissioners who heard the merger application had been subject to ex parte contact with executives from Great Plains, Public Counsel did not overcome the presumption that the PSC acted impartially. View "State ex rel. Praxair, Inc. v. Mo. Pub. Serv. Comm'n " on Justia Law

On the last day of a three-year limitations period, Eric Katz filed a lawsuit alleging medical malpractice in the death of his mother. After discovery, Katz amended the petition by adding several defendants and dropping others. At the time of the amendment, the statute of limitations had expired. Only one defendant named within the limitations period remained in the case. The newly added defendants moved to dismiss on the ground that the action was not commenced against them within the limitations period and that the amendment adding them did not relate back to the date of the original filing. The circuit court overruled the motions to dismiss, and the new defendants filed petitions for writs of prohibition. The two separate writ petitions were consolidated for decision. The Supreme Court issued preliminary writs for the petitions. The Court held that the amended petition did not relate back to the filing of the initial petition, and therefore, the statute of limitations barred Katz's lawsuit for wrongful death against the new defendants. The preliminary writs in this case were made permanent. View "State ex rel. Holzum v. J. Schneider" on Justia Law