Justia Missouri Supreme Court Opinion Summaries
Articles Posted in Missouri Supreme Court
City of St. Louis v. State
The City of St. Louis appealed the trial court's holding that the prohibition against special laws contained in Mo. Const. art. III, 40 was not violated by Mo. Rev. Stat. 320.097. That statute exempted certain veteran firefighters who lived in areas with unaccredited or provisionally accredited school districts from any local laws requiring them to live in their home district. The State also appealed, alleging (1) the trial court erred in holding that section 320.097 violated what the trial court believed was the "broad measure of complete freedom from State legislative control" given to constitutional charter cities by the Missouri Constitution, and (2) the trial court erred in holding that the statute violated the equal protection clauses of the Missouri and U.S. constitutions because it was not rationally related to any legitimate purpose. The Supreme Court (1) affirmed the trial court's holding that the statue was not a special law in violation of the Missouri Constitution; (2) reversed the trial court's holding that the statute violated the state constitution because it interfered with the City's right to set its employees' and officers' powers, duties and compensation; and (3) reversed the trial court's holding that the statute violated equal protection guarantees.
View "City of St. Louis v. State" on Justia Law
Taylor v. State
A jury found Appellant guilty of four counts of first-degree murder and armed criminal action for the shooting deaths of his girlfriend and her three children. Appellant was sentenced to death for his crimes. Appellant subsequently filed a motion for post-conviction relief, alleging ineffective assistance of counsel. After an evidentiary hearing regarding some of Appellant's claims, the motion court overruled his motion. The Supreme Court affirmed, holding that Appellant failed to make a sufficient showing to support Strickland v. Washington's prejudice prong because of the overwhelming evidence presented that established his guilt, and therefore, the motion court did not err in overruling the motion. View "Taylor v. State" on Justia Law
State v. Jackson
The State issued a warrant for Defendant's arrest after it was discovered that he was secretly videotaping clients while they undressed at his massage therapy business. Defendant was arrested and sought release on bail. Pursuant to Mo. R. Crim. P. 33.01, the circuit court set a $75,000 cash-only bond. Defendant sought relief of the court's order, arguing that the setting of a cash-only bond violates the requirement of Mo. Const. art. I, 20 that the bail shall be permitted by "sufficient sureties." After considering the purposes and the history of bail as well as the numerous understandings of the word "sufficient surety," the Supreme Court held that the trial court did not err in exercising its discretion to require a cash-only bond, as the imposition of a cash-only bail does not violate the Missouri Constitution. View "State v. Jackson" on Justia Law
Williams v. State
Appellant was found guilty by a jury of robbery in the first degree, armed criminal action, and unlawful use of a weapon. The appellate court affirmed. Appellant filed a Mo. R. Crim. P. 29.15 motion, alleging his trial counsel was ineffective for not calling a witness to testify and because his appellate counsel was ineffective in failing to raise a meritorious issue on appeal. The circuit court overruled Appellant's motion without a hearing. The Supreme Court affirmed because (1) the testimony of the witness did not negate an element of the crime and would not produce a viable defense, and (2) Williams could not demonstrate a reasonable probability that the outcome wold have been different had his appellate counsel raised the sufficiency of the evidence claim on appeal. View "Williams v. State" on Justia Law
State v. Wright
Appellant was found guilty by a jury of the unlawful use of a weapon pursuant to Mo. Rev. Stat. 571.030.1. Appellant appealed, arguing that the circuit court erred in overruling his motion for a judgment of acquittal because there was insufficient evidence presented at trial that the weapon was concealed and that the weapon was a functional lethal weapon. The Supreme Court granted transfer after opinion by the court of appeals. The Court then affirmed the circuit court's judgment, holding (1) the evidence was sufficient to find Appellant concealed the firearm on or about his person; and (2) section 571.030.1 does not require the State to introduce evidence of the firearm's "functionality" in order to gain a conviction for the unlawful use of a weapon.
View "State v. Wright" on Justia Law
State v. Stover
Defendant was convicted and sentenced to twelve years without probation or parole for the class A felony of trafficking drugs in the first degree. On appeal, Defendant claimed, inter alia, that the trial court erred in overruling his objection to a verdict-directing instruction because it did not require the jury to find Defendant knew of the substance's content and character. The Supreme Court reversed, holding (1) the trial court's failure to instruct the jury to find that Defendant knew the content or character of the drugs relieved the State of its burden of proving each element of the offense beyond a reasonable doubt; and (2) this failure was plain error and required the reversal of Defendant's conviction and sentence. Remanded for a new trial. View "State v. Stover" on Justia Law
Bob DeGeorge Assocs., Inc. v. Hawthorn Bank
Hawthorn Bank appealed the trial court's entry of summary judgment in favor of Plaintiffs on Hawthorn Bank's claim that its purchase-money deed of trust being recorded after the mechanics' liens attached to the property. Hawthorn Bank asserted that purchase-money deeds of trust are always superior in priority to mechanics' liens under Missouri law and that the recording statutes, Mo. Rev. Stat. 442.380 and 442.400, do not govern the relative priority of a purchase-money deed of trust over a mechanic's lien. The Supreme Court affirmed the judgment of the trial court, holding that because sections 442.380 and 442.400 provided that Hawthorn Bank's purchase-money deed of trust was not valid until recorded and because the mechanics' liens attached before it was recorded, the purchase-money deed of trust was a subsequent encumbrance that was inferior in priority to the mechanics' liens. View "Bob DeGeorge Assocs., Inc. v. Hawthorn Bank" on Justia Law
Beard v. Mo. State Employees’ Ret. Sys.
As a state employee, Laurel Beard was a member of the Missouri State Employees' Retirement System (MOSERS). Beard filed for retirement but died before her annuity start date. Following Beard's death, Plaintiffs, Beard's assigned heirs, requested MOSERS to distribute Beard's retirement benefits to them as Beard's designated beneficiaries. MOSERS' board of trustees determined Plaintiffs were not entitled to retirement or survivor benefits because Beard died prior to her annuity starting date and did not have a surviving spouse or dependent children. Plaintiffs filed suit, seeking review of the MOSERS decision denying benefits. The trial court entered judgment in favor of MOSERS. Plaintiffs appealed, alleging the trial court wrongly interpreted Mo. Rev. Stat. 104.1030 in denying them retirement benefits. The Supreme Court affirmed, holding (1) the trial court properly applied the plain language of section 104.1030; and (2) section 104.1030 is constitutional for vested members of MOSERS who have filed for retirement but die before their annuity start date. View "Beard v. Mo. State Employees' Ret. Sys." on Justia Law
Whelan Security Co. v. Kennebrew
Whelan Security Company appealed a trial court's grant of summary judgment in favor of Charles Kennebrew and W. Landon Morgan on its action to enforce the non-compete agreements it had with Kennebrew and Morgan. On appeal, Whelan claimed that the trial court erred in concluding that the non-competition and non-solicitation clauses were invalid as overbroad and unreasonable as to time and space. The Supreme Court granted transfer and reversed, holding that the non-compete agreements were unreasonable as written but modified the terms of the agreements to give effect to the intent of the parties in entering the non-compete agreement; and (2) because genuine factual issues existed, entry of summary judgment was improper. Remanded. View "Whelan Security Co. v. Kennebrew" on Justia Law
State ex rel. SLAH, LLC v. City of Woodson Terrace
This case involved a challenge to the imposition of municipal taxes on SLAH, LLC, a business entity that owned a hotel located in the city of Woodson Terrace. The city appealed from the declaratory judgment entered against it on SLAH's claim that the city was prohibited by Mo. Rev. Stat. 94.270.3 from imposing a hotel license tax rate in excess of $13.50 per room, per year. The Supreme Court reversed, holding (1) the remedy afforded to SLAH under Mo. Rev. Stat. 139.031 was adequate under the circumstances, and accordingly, it was the exclusive remedy for challenging the legality of the city's hotel license tax rates; and (2) because a declaratory judgment action is improper when an adequate remedy exists at law, the trial court erred in entering judgment in favor of SLAH. View "State ex rel. SLAH, LLC v. City of Woodson Terrace" on Justia Law