Justia Missouri Supreme Court Opinion Summaries

This was the fifth action to come before the Supreme Court involving murders committed in 1996 by Carman Deck. Deck filed this Mo. R. Crim. P. 29.15 post-conviction proceeding, asserting (1) his counsel at the penalty phase of his capital murder trial was ineffective for failing to call certain witnesses and for other alleged deficient performance, and (2) the motion court erred in denying his motion for a new trial. The Supreme Court affirmed the denial of Rule 29.15 relief and the denial of Deck's request for a new trial, holding (1) the motion court did not clearly err in finding that counsel was not ineffective; and (2) Deck was not entitled to a new trial based on the trial court's alleged destruction of juror questionnaires. View "Deck v. State" on Justia Law

Jamilah Nasheed appealed from the trial court's judgment in favor of Robin Wright-Jones on Wright-Jones' petition challenging the qualifications of Nasheed to run for election in the Democratic Party primary for state senator for the 5th district. The trial court found the residency requirement of the Missouri Constitution was ambiguous and Nasheed did not satisfy that requirement to run in the 5th district. An exception in Mo. Const. art. III, 6 provides that if the repportionment of the districts is less than one year before the general election, candidates may reside in any district from which a portion was incorporated into the new district where the candidate seeks office, even if the candidate does not reside in that incorporated portion. The Supreme Court reversed, holding that Nasheed was eligible to run in the 5th district because the exception did not require Nasheed to live within the boundaries of the reapportioned senate district she sought to represent. View "Wright-Jones v. Nasheed " on Justia Law

Rochelle Gray appealed from the judgment of the trial court in favor of Sylvester Taylor on Gray's petition challenging the qualifications of Taylor to run for election in the Democratic Party primary for state representative in the 75th district. The trial court held that although Taylor did not reside within the boundaries of the new district, the Missouri Constitution required only that he have resided for one year in the county or any of the district from which the new district was created through reapportionment. The Supreme Court affirmed, holding that, in the context of reapportionment within one year of a general election, the Constitution requires that a candidate satisfies the one-year residency requirement by residing in the county or any district from which a portion was incorporated in the new district where the candidate seeks office, even if the candidate does not reside in that portion. View "Gray v. Taylor" on Justia Law

After a bench trial, Elton Norfolk was found guilty of one count of unlawfully carrying a concealed weapon and one count of possession of marijuana. Norfolk appealed, arguing that the circuit court clearly erred in overruling his motion to suppress evidence and his objections to the admission of evidence seized because the police officer lacked reasonable suspicion to stop him and check for a weapon. The Supreme Court affirmed the judgment of the circuit court, holding that Forfolk's Fourth Amendment rights were not violated, the evidence seized was properly admitted, and there was sufficient evidence to support the convictions. View "State v. Norfolk" on Justia Law

Zane Valentine pleaded guilty to one count of child molestation in the first degree and three counts of statutory sodomy in the second degree. The plea agreement provided that Valentine would be placed in the Sex Offender Assessment Unit (SOAU), and the circuit court stated it would retain jurisdiction over Valentine for 120 days while he was assessed. The circuit court then sentenced Valentine. The SOAU later recommended the circuit court grant Valentine probation. More than 120 days after Valentine was sentenced the circuit court entered an order denying Valentine's release on probation. On reconsideration, the circuit court found that Valentine had not completed a "program" as defined in Mo. Rev. Stat. 559.115, and therefore, the court had authority to deny Valentine probation after the statutory time limits set forth in the statue had passed. The Supreme Court granted Valentine a writ of mandamus and ordered the circuit court to release Valentine on probation, holding (1) the SOAU is a 120-day program under section 559.115; and (2) therefore, the circuit court abused its discretion by denying Valentine's release on probation when the order was entered beyond the statutory time limits set forth in section 559.115. View "State ex rel. Valentine v. Circuit Court (Orr) " on Justia Law

Lonnie Lewis died when the tractor trailer in which he was a passenger overturned. The driver of the truck, Nathan Gilmore, was employed by Buddy Freeman, and Freeman operated the tractor trailer pursuant to a contract with DOT Transportation. Neither Freedman nor DOT carried workers' compensation insurance. Lewis' dependents filed a claim for workers' compensation against Freeman and DOT and a wrongful death action against Freeman and Gilmore. An ALJ entered an award in favor of Lewis' dependents. After the entry of the workers' compensation award, DOT intervened in the Lewises' wrongful death action. The circuit court granted summary judgment in favor of Gilmore and Freeman, finding the wrongful death action was barred because the Lewises had made an election of remedies when they obtained a workers' compensation award against DOT. The Supreme Court reversed, holding that the Lewises' civil action against Freeman was not barred by their workers' compensation award from DOT, as Mo. Rev. Stat. 287.280 allowed the Lewises to proceed in a civil action against Freeman as a result of his failure to insure his liability under the Missouri workers' compensation laws even though the Lewises obtained a workers' compensation award against DOT. View "Lewis v. Gilmore" on Justia Law

Respondent Danny Vaughn was charged with one count of burglary and one count of harassment. Both charges contained harassment elements. Upon a motion by Respondent, the motion court dismissed both counts, concluding that Mo. Rev. Stat. 565.090.1(5) and 565.090.1(6) were vague and overbroad. The Supreme Court affirmed in part and reversed in part, holding (1) section 565.090.1(5) criminalizes communication protected by the First Amendment and is unconstitutionally overbroad; but (2) as construed, section 565.090.1(6) is not overly broad, provides a reasonable notice of the conduct it prohibits, and provides a sufficiently concrete standard so as to mitigate the potential for arbitrary enforcement. View "State v. Vaughn" on Justia Law

After a jury trial, Vincent McFadden was found guilty of first-degree murder and armed criminal action. Consistent with the jury's recommendation, McFadden was sentenced to death. The Supreme Court affirmed, holding (1) the trial court did not err in limiting the testimony of a defense witness; (2) McFadden was not subjected to double jeopardy; (3) the trial court did not err in striking a venireperson for cause or in denying McFadden's Batson challenge as to a venireperson; (4) the trial court did not plainly err during the guilt phase of McFadden's trial in admitting certain testimony; (5) the trial court properly instructed the jury; (6) the State did not violate McFadden's due process rights during all phases of the trial; (7) the trial court did not improperly admit hearsay into evidence; and (8) the imposition of the death penalty met the statutory requirements. View "State v. McFadden" on Justia Law

David Liberty was convicted of one felony count of first-degree promoting child pornography and eight felony counts of first-degree possession of child pornography. Liberty alleged that the evidence the State presented to insufficient to convict him of the charges. The Supreme Court (1) affirmed Liberty's conviction for promoting child pornography and one of his convictions for possession of child pornography, as the evidence was sufficient to support the verdict; but (2) reversed the remaining convictions for possession of child pornography, holding that the imposition of eight separate sentences for one instance of possession violated Liberty's constitutional protections against double jeopardy, as Mo. Rev. Stat. 573.037 did not ambiguously permit separate prosecutions for each image a defendant simultaneously possessed. This holding, however, did not preclude the State from retrying Liberty on the reversed charges, as double jeopardy principles did not bar Liberty's retrial. Remanded. View "State v. Liberty" on Justia Law

Sandy Johme was employed by St. John's Mercy Healthcare as a billing representative, and her work involved typing charges at a computer in an office. After making a pot of coffee at an office kitchen at work, Johme fell and injured herself. Johme was "clocked-in" as an employee at the time of her fall. The Labor and Industrial Relations Commission awarded workers' compensation benefits to Johme after applying Mo. Rev. Stat. 287.020.3(2). The Supreme Court reversed the Commission's decision, holding that Johme was not entitled to workers' compensation benefits because she failed to show that her injury arose out of and in the course of her employment as specified in section 287.020.3(2). View "Johme v. St. John's Mercy Healthcare" on Justia Law