Justia Missouri Supreme Court Opinion Summaries

A construction crane owned and operated by a construction company (Jacobsmeyer) fell on a building. Jacobsmeyer's insurer (Travelers) reached a settlement agreement with the designer and manufacturer of the crane (Grove) wherein Grove agreed to pay Jacobsmeyer and Travelers (hereinafter referred to collectively as Jacobsmeyer) for a majority of their remaining losses associated with the accident. Jacobsmeyer subsequently sued Grove and its parent company (hereinafter referred to jointly as Manitowoc) for breach of the settlement agreement. Manitowoc filed third-party petition claims for contribution and/or indemnity against U.S. Steel, alleging that U.S. Steel's predecessor-in-interest provided the faulty steel for the crane. The trial court dismissed Manitowoc's third-party petition with prejudice because Manitowoc failed to satisfy pleading requirements where it did not admit its own liability as a joint tortfeasor in its third-party petition. The Supreme Court reversed, holding that a party seeking contribution or indemnity need not admit its own fault in its third-party petition but rather can deny liability in its answer to the plaintiff's petition and assert in its third-party petition that if it is liable to the plaintiff, then the third-party defendant is liable to it. Remanded. View "Travelers Prop. Cas. Co. of Am. v. Manitowoc Co., Inc." on Justia Law

After a jury trial, Plaintiff was found guilty of first-degree murder and armed criminal action. The circuit court sentenced Defendant to death. The Supreme Court affirmed the judgment, holding (1) the trial court did not plainly err in its rulings regarding the jury and jury instructions; (2) the prosecutor did not engage in improper arguments or make improper comments; (3) the trial court did not err in its evidentiary rulings; (4) the trial court did not err in its rulings during the penalty phase; and (5) in this case, the death penalty complied with all statutorily proportionality requirements. View "State v. McFadden" on Justia Law

Plaintiffs brought suit against multiple health services providers (Defendants), alleging they were victims in a scheme of improper surgical billing by Dr. Richard Coin and his business, Reconstructive Microsurgery Associates. The circuit court granted summary judgment in favor of Defendants, concluding that Plaintiffs had not shown they were damaged by the health services providers' alleged wrongdoing. The Supreme Court affirmed, holding (1) Plaintiffs had sufficient standing in this action; but (2) summary judgment was warranted because establishing damages was an essential element of Plaintiffs' claims, and they did not show they suffered any damages. View "Roberts v. BJC Health Sys." on Justia Law

In 2010, the General Assembly enacted the Missouri Secure and Fair Enforcement Mortgage Licensing Act (Missouri SAFE Act), which provides that the director of the Missouri Division of Finance shall not issue a mortgage loan originator license to an applicant who has been convicted of or pleaded guilty to a felony within seven years prior to the date of the application. When Plaintiff subsequently submitted an application for a mortgage loan originator license, the director denied the license pursuant to the Act because Plaintiff had pleaded guilty to a felony in 2006. The circuit court entered a declaratory judgment finding that the Act was unconstitutional as applied to Plaintiff. The Supreme Court reversed, holding that, as applied to Plaintiff, the statute (1) was not an unconstitutional bill of attainder; (2) did not violate the Missouri Constitution's ban on retrospective laws; and (3) did not violate Plaintiff's right to procedural and substantive due process. View "Garozzo v. Mo. Dep't of Ins., Div. of Fin." on Justia Law

Allegations of sexual abuse were made against Allen Austin (Decedent) in 2006. Decedent died in 2009. A personal representative of Decedent's estate failed to provide actual notice of the probate proceeding to the children whom Decedent was alleged to have sexually abused. Because of the failure to notify the children, their claims against the estate were filed beyond the statutory six-month window for creditors to file claims against the estate. The trial court dismissed the claims as tardy as the children were not "known or reasonably ascertainable creditors." The Supreme Court reversed, holding (1) the children were known or reasonably ascertainable creditors of the estate, and therefore, their claims were more than merely conjectural; and (2) because due process requires that the personal representative of an estate provide actual notice of the probate proceeding to all reasonably ascertainable creditors of the estate who may have more than a merely conjectural claim against the estate, the children's claims should not have been dismissed. View "Estate of Austin v. Snead" on Justia Law

After a jury trial, Defendant was convicted of two counts of harassment, one under Mo. Rev. Stat. 565.090.1(2) and one under section 565.090.1(5), and one count of possession of marijuana. The harassment charges stemmed from emails Defendant sent to public officials that contained personally offensive language and references to sawed-off shotguns, assassinations, and domestic terrorism. The Supreme Court affirmed in part and reversed in part, holding (1) the content of Defendant's emails did not constitute protected speech, and therefore, section 565.090.1(2) was constitutional as applied to Defendant, and there was sufficient evidence to support his conviction on that count; and (2) the judgment as to the second count of harassment was set aside, as State v. Vaughn invalidated section 565.090.1(5), and manifest injustice would result if the conviction under that statute was not reversed. View "State v. Wooden" on Justia Law

After a jury trial, Defendant was convicted of murder, assault, burglary, and armed criminal action. Defendant subsequently filed a petition for writ of habeas corpus, petitioning the Supreme Court to vacate his convictions and to grant him a new trial because newly discovered evidence showed (1) the State violated Brady v. Maryland by withholding material, favorable evidence, and (2) the lack of disclosure of this Brady material was prejudicial. After a hearing, a special master found that the State had violated Brady in at least two important and material respects and that the State's failure to produce this Brady material was prejudicial. The Supreme Court concluded that substantial evidence supported the master's findings and, accordingly, ordered that Defendant's convictions be vacated and ordered him discharged from the custody of the department of corrections unless the State filed in the circuit court an election to retry him. View "State ex rel. Woodworth v. Denney" on Justia Law

Appellant suffered extensive injuries while riding a motorcycle that was hit by a vehicle driven by Tortfeasor. Appellanat recovered $100,000 from Tortfeasor's insurance company, which left Appellant with $1.4 million in unpaid damages. Appellant sought additional recovery under the underinsured motorist coverage endorsement of the American Family policy he had purchased for the motorcycle and under the underinsured motorist coverage endorsements of each of the additional American Family insurance policies he had purchased for his two trucks. He also sought recovery as an additional insured on the American Standard policy his father maintained for a motorcycle. Both insurers denied coverage under all of these four policies. Appellant then joined both insurers as additional defendants, claiming he was entitled to $400,000 in underinsured motorist coverage under the four policies. The trial court granted summary judgment in favor of the insurers, holding that the policies' owned-vehicle exclusions unambiguously applied to the motorcycle he was riding at the time of the accident. The Supreme Court reversed, holding (1) Tortfeasor's vehicle was an underinsured motor vehicle; (2) the insurers failed to show that the owned-vehicle exclusion applied; and (3) the "other insurance" clause permitted stacking of the underinsured motorist coverage, and offset was not permitted. View "Manner v. Schiermeier" on Justia Law

Appellants, Father and Son, were arrested for driving while intoxicated during separate traffic stops. Preliminary breath tests showed Appellants' blood-alcohol contest to be over the legal limit. Father agreed to take a breathalyzer test but refused to provide sufficient breath to perform the test, and Son refused to take the breathalyzer test. The director of revenue revoked Appellants' driving privileges for one year. Appellants filed petitions for review, which the circuit court denied. Appellants appealed, asserting (1) the trial court violated their due process rights by admitting the director's records into evidence without providing them the opportunity to confront and cross-examine the director's witnesses who created the records; and (2) Mo. Rev. Stat. 302.312, which authorizes the admission of the director's records in evidence in court and administrative proceedings, is unconstitutional. The Supreme Court affirmed, holding that the provision of section 302.312 authorizing the admission of the director's records by the trial court did not deny Appellants their constitutional rights to confrontation and cross-examination, as Appellants had the right to subpoena witnesses to appear at the trials on their petitions for review. View "Doughty v. Dir. of Revenue" on Justia Law

American Airlines submitted a request to the director of revenue for a refunds of sales tax it alleged it overpaid between 2004 and 2007, asserting that its sales of aviation jet fuel to two of its contractors were not subject to taxation under Mo. Rev. Stat. 144.020 because they did not constitute "sales at retail" as defined by Mo. Rev. Stat. 144.010. American asserted that it never transferred title or ownership of the fuel to the purchasers because it restricted the use of the purchased fuel so as to exercise dominion and control over it. The director denied American's request. American filed a complaint with the administration hearing commission, which determined that American was not entitled to a refund. The Supreme Court affirmed, holding (1) the record supported the factual determination that, upon delivery of the fuel, American transferred title and ownership to its contractors; and (2) therefore, the transactions constituted "sales at retail" and were subject to taxation under section 144.020. View "Am. Airlines, Inc. v. Dir. of Revenue" on Justia Law