Justia Missouri Supreme Court Opinion Summaries

Appellants Reva Billings and William Morrison worked at a Western Union Financial Services (Western Union) call center in Bridgeton. On July 3, 2008, Western Union advised Billings that she would be laid off on July 20 and Morrison that he would be laid off on August 7. The U.S. Department of Labor determined the employees were eligible for Trade Act benefits and set the impact date as July 15, 2008. Appellants subsequently applied for their benefits. The Missouri Division of Employment Security denied benefits to both on the grounds that they were separated from employment prior to the impact date, finding the date of separation for Appellants to be July 3, 2008. The Industrial Relations Commission affirmed. The Supreme Court reversed and remanded, holding that the Commission erred in considering Appellants to have ceased work on the date they received their contractually required advance notice of the future dates on which they would be furloughed, as the correct dates were the dates Appellants' furloughs became effective, notwithstanding that Western Union chose not to be physically present at the workplace during the notice period. View "Billings v. Div. of Employment Sec." on Justia Law

Darren Berry filed suit against Volkswagen, alleging violations of the Missouri Merchandising Practices Act (MMPA). The trial court certified a class on behalf of Missouri owners and lessors of Volkswagen vehicles (Class). The action settled. After the the settlement for Class was approved and paid out, the trial court held a hearing regarding attorneys' fees. The trial court awarded Class counsel attorney's fees after determining the lodestar amount to be $3,087,320 and applying a multiplier of 2.0 for a total award of $6,174,640 in attorneys' fees. Volkswagen challenged the award of attorneys' fees. The Supreme Court affirmed, holding (1) the lodestar amount was within the trial court's discretion; and (2) the multiplier applied to the lodestar amount was not an abuse of the trial court's discretion. Remanded. View "Berry v. Volkswagen Group of Am., Inc." on Justia Law

Employee was terminated from her employment after her driver's license was suspended due to her epilepsy. Employee filed this action against Employer, alleging discrimination and retaliation in violation of the Missouri Human Rights Act (MHRA). The jury returned a verdict in favor of Employee in the amount of $11,250 for compensatory damages. Employee filed a motion for additur or, in the alternative, a new trial. The circuit court sustained Employee's motion and gave the parties thirty days to accept a higher amount of compensatory damages or elect a new trial on these damages only. Employer would not agree to an enhanced compensatory damage award, and the circuit court ordered a new trial on the basis that the verdict was against the weight of the evidence. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion in sustaining Employee's motion; and (2) the circuit court did not abuse its discretion in ordering a new trial on the issue of compensatory damages only. View "Badahman v. Catering St. Louis" on Justia Law

Respondent filed a declaration of candidacy to run for the position of Director of Community Fire Protection District (Community Fire). Community Fire accepted Respondent's declaration of candidacy, but Respondent was subsequently disqualified because his financial interest statement had not been timely filed. Fire Chief Charles Coyne filed a petition requesting the circuit court enter an order directing Respondent to show cause why his name should not be stricken from the ballot. The trial court ruled that Respondent was disqualified from running for the position and ordered that his name be removed from the ballot. The Supreme Court affirmed, holding that the trial court did not err in its judgment, as (1) Chief Coyne had capacity to bring this action on behalf of Community Fire, which had standing to bring the action; (2) Respondent received adequate notice of his obligation to file a financial interest statement; and (3) the statutory financial interest statement notice requirements are constitutionally valid. View "Coyne v. Edwards" 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

This appeal involved Missouri Senate Bill No. 7 (SB 7), which enacted fourteen new sections relating to science and innovation, with a contingent effective date. Section B of the Act hinged the effectiveness of SB 7 upon the passage of Senate Bill No. 8 (SB 8), which related to taxation. Despite the failure of the General Assembly to pass SB 8, various agencies began to implement Section A of SB 7 regarding science and innovation. Missouri Roundtable for Life, Inc. (Roundtable) filed suit seeking to enjoining the implementation of SB 7 and reverse any actions already taken to execute its provisions. The circuit court concluded that SB 7 was unconstitutional in its entirety as a violation of the single subject provision of Mo. Const. art. III, 23. The Supreme Court affirmed, holding that the record supported (1) the circuit court's conclusion that SB 7 is unconstitutional in its entirety as a violation of the single subject provision of article III, section 23, and (2) the court's factual finding and legal conclusion that Section B could not be severed from the remainder of SB 7 under the facts of this case. View "Mo. Roundtable for Life, Inc. v. State" on Justia Law

After John Doe's HIV test results were sent by Quest to the church where Doe worked as personal assistant to the pastor, Doe filed suit against Quest Diagnostics Clinic Laboratories (Quest Laboratories) and its parent, Quest Diagnostics, alleging wrongful disclosure of HIV test results and breach of fiduciary duty. The trial court (1) entered a directed verdict in favor of Quest Diagnostics on the ground it was a separate corporation from Quest Laboratories and did not exercise such control over the latter that the corporate veil should be pierced; and (2) found in favor of Quest Laboratories on both counts. The Supreme Court reversed the judgment in favor of Quest Laboratories, holding that the trial court (1) committed prejudicial error in submitting an affirmative defense instruction requiring the jury to find for Quest Laboratories if it found Doe gave it "written authorization" to disclose his HIV test results, as the instruction was not supported by the evidence; and (2) erred in submitting Doe's claim of breach of fiduciary duty, as an adequate remedy at law already existed under Missouri statute. Remanded. View "Doe v. Quest Diagnostics, Inc." on Justia Law

After a jury trial, Defendant was convicted of first-degree robbery, forcible rape, attempted forcible rape, and forcible sodomy. Defendant appealed, claiming (1) the trial court erred in admitting into evidence his incriminating statements to police because the statements were made involuntarily in reliance on an agreement the state failed to honor, and (2) there was insufficient evidence to support his conviction of two separate counts of first-degree robbery. The Supreme Court (1) vacated Defendant's for first-degree robbery as charged in the second count based on the state's concession Defendant was wrongfully subjected to multiple convictions for taking multiple items of property from the victim in the course of a single incident; and (2) affirmed the judgment in all other respects, holding that the trial court did not err in admitting Defendant's pretrial statements, as the facts clearly supported the trial court's finding that Defendant's statements were voluntary. View "State v. Hicks" on Justia Law

In 2008, St. Charles County and Laclede Gas Company entered into litigation disputing which party would bear the expense of relocating Laclede Gas' lines due to the County's road project. The circuit court entered summary judgment in favor of the County. The Supreme Court reversed and remanded the case. The County then filed a motion to voluntarily dismiss its litigation under Mo. R. Civ. P. 67.02. The circuit court overruled the County's motion, reasoning that a voluntary dismissal was improper under Rule 67.02 because the case was previously resolved by summary judgment. The County subsequently sought a writ of prohibition, claiming that the circuit court acted outside its jurisdiction by denying the County's motion to voluntarily dismiss its 2008 action against Laclede Gas. The Supreme Court quashed its preliminary writ, holding that the circuit court did not err in overruling the County's motion to dismiss, as the motion was not filed prior to the introduction of evidence at trial, and allowing the County to dismiss its case after it was reviewed by the Court would result in the County achieving an undue advantage in that it would circumnavigate the Court's prior opinion. View "State ex rel. St. Charles County v. Circuit Court" on Justia Law

In 2001, Taxpayers bought two parcels located within a residential subdivision that was zoned residential. In 2009, the county assessor reclassified the property from residential to agricultural. The assessor assumed a commercial use on the property and thus valued it as commercial. The county board of equalization affirmed the assessor's determinations. Taxpayers appealed to the State Tax Commission (STC). A hearing officer found the appropriate classification for the property was commercial and that it should be assessed at the commercial rate as opposed to the agricultural rate. The STC affirmed the hearing officer's decision. The circuit court affirmed the STC's decision as being supported by competent and substantial evidence. The Supreme Court affirmed, holding that the STC's application of the factors set forth in Mo. Rev. Stat. 137.016.5 to Taxpayers' property was supported by substantial and competent evidence in the record. View "Bateman v. Rinehart" on Justia Law