Justia Missouri Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the circuit court dismissing Petitioner's petition seeking relief from fraudulent transfers Respondent made to hinder collection of her judgments against him, holding that Petitioner adequately alleged facts that, if true, entitled her to relief under the Uniform Fraudulent Transfers Act (UFTA), Mo. Rev. Stat. 428.005 to 428.059.On appeal, Petitioner argued that she alleged facts that, if taken as true, demonstrated that she was Respondent's creditor and that he made two transfers with the actual intent to hinder, delay, or defraud her and, regarding one of the transfers, without receiving an equivalent value in exchange and either was insolvent or became insolvent as a result of the transfer. The Supreme Court agreed and remanded the case, holding that Petitioner adequately pleaded a claim for relief under both Mo. Rev. Stat. 428.024.1(1) and Mo. Rev. Stat. 928.029.1. View "Konopasek v. Konopasek" on Justia Law

The Supreme Court quashed a preliminary writ of prohibition granted to the Kristine and Dennis Hill preventing the circuit court from compelling production of certain settlement documents relating to a motor vehicle accident involving Kristine in this negligence lawsuit brought against Mercy Rehabilitation Hospital, holding that the documents were not protected by the work product doctrine.Kristine was a patient at Mercy recovering from back surgery when her hospital bed allegedly malfunctioned in a manner causing her to sustain back and spine injuries. Six months later, Kristine was involved in an accident that allegedly aggravated those injuries. After Kristine settled her claim with the insurance carrier of the at-fault driver the Hills sued Mercy, alleging negligence. Mercy sought production of the settlement documents to prove reduction, but the Hills identified as protected work product several of those documents. The circuit court sustained Mercy's ensuing motion to compel production of the documents, and the Halls petitioned for a writ of prohibition. The court of appeals issued a preliminary writ. The Supreme Court quashed the writ, holding that the circuit court properly concluded the settlement documents and related communications Mercy sought were not protected by the work product doctrine. View "Hill v. Honorable Wallach" on Justia Law

The Supreme Court affirmed the judgment of the circuit court sustaining the motion to dismiss filed by the City of St. Charles due to Plaintiff's failure to provide notice of suit, as required by section 12.3 of the City of St. Charles Charter, holding that Plaintiff's claims on appeal failed.Plaintiff filed a lawsuit against the City of St. Charles and St. Charles County seeking damages incurred as a result of falling off his bike while riding across an open-grated metal bridge, alleging negligence and premises liability. The City filed a motion to dismiss, arguing that the premises liability claim was barred because Plaintiff failed to give proper notice, as required by section 12.3 of the Charter. The circuit court sustained the motion and dismissed the premises liability claim. Plaintiff appealed, arguing that the Charter's notice requirement conflicted with various statutes and must be stricken. The Supreme Court affirmed, holding that there was no irreconcilable conflict between section 12.3 of the Charter and the statutes cited by Plaintiff. View "Zang v. City of St. Charles" on Justia Law

The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission affirming and adopting the ALJ's final award denying Appellant's claim for benefits from the Second Injury Fund, holding that the Commission did not abuse its discretion in affirming the ALJ's denial of Appellant's post-hearing motions to reopen the record and submit additional evidence.Before the ALJ issued her final award, the Supreme Court decided Cosby v. Treasurer of Missouri, 579 S.W.3d 202 (Mo. banc 2019), which reached a different interpretation of Mo. Rev. Stat. 287.220.3 than that reached by the court of appeals in Gattenby v. Treasurer of Missouri, 516 S.W.3d 859 (Mo. App. 2017). Before the ALJ's final award, Appellant filed a motion to reopen the record for a supplemental hearing based on Cosby. The ALJ overruled the motion and issued her award. The Commission affirmed. The Supreme Court affirmed, holding that the Commission did not abuse its discretion in overruling Appellant's motions to reopen the record and submit additional evidence. View "Weibrecht v. Treasurer of Mo. as Custodian of Second Injury Fund" on Justia Law

The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission overruling James Swafford's claim for permanent total disability (PTD) benefits from the Second Injury Fund, holding that Swafford was not entitled to reversal as to his claims on appeal.In denying benefits, the Commission determined that Swafford failed to show that his preexisting disabilities" directly and significantly aggravated or accelerated" his primary injury pursuant to Mo. Rev. Stat. 287.220.3(2)(a)a(iii). On appeal, Swafford argued that the Commission improperly disregarded the expert testimony he proffered to establish a causal relationship between his primary injury and his preexisting disabilities. The Supreme Court affirmed, holding that the Commission's findings were supported by substantial and competent evidence and that Swafford failed to establish that his primary injury and preexisting disabilities entitled him to PTD benefits from the Fund. View "Swafford v. Treasurer of Missouri as Custodian of Second Injury Fund" on Justia Law

The Supreme Court made permanent a preliminary writ of prohibition it issued directing the circuit court to vacate its order denying Missouri Highway Patrol Trooper Mayela Barron's motion for summary judgment and sustain Trooper Barron's motion for summary judgment against Justin Osborn, holding that Trooper Barron was entitled to official immunity.Osborn brought this action alleging negligence claims against Trooper Barron in her official capacity after Osborn's vehicle collided with Trooper Barron's vehicle. Osborn moved for partial summary judgment, arguing that Trooper Barron was not entitled to official immunity or immunity because of the public duty doctrine. The circuit court denied the motion and granted partial summary judgment for Osborn, concluding that Trooper Barron was not entitled to official immunity. The Supreme Court granted a writ of prohibition, holding (1) the record established that Trooper Barron was a public official, working in the scope of her employment, performing a function that was not ministerial, and Trooper Barron performed these duties without malice; and (2) therefore, Trooper Barron was entitled to official immunity, and a writ of prohibition was appropriate. View "State ex rel. Barron v. Honorable Beger" on Justia Law

The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission denying Claimant's claim for permanent total disability (PTD) benefits from the Second Injury Fund, holding that the Commission appropriately found that Claimant was not permanently and totally disabled.Claimant filed an amended workers' compensation claim against Employer, alleging that his primary work-related injuries were "bilateral upper extremities" and asserting a claim against the Fund for PTD benefits due to a prior injury to his bilateral lower extremities. An administrative law judge denied PTD benefits, and the Commission affirmed. The Supreme Court affirmed, holding that Claimant failed to carry his burden of persuasion in demonstrating that he was entitled to PTD benefits. View "March v. Treasurer of Missouri" on Justia Law

The Supreme Court vacated the order of the circuit court entering summary judgment in favor of Alexis Still in this dispute over whether there was a settlement agreement between the parties, holding that there was no settlement agreement between the parties.Clifton Jameson and Still were involved in an automobile accident. Jameson sent MetLife, Still's insurer, an offer to settle. MetLife made a counteroffer. Jameson took the counteroffer as a rejection of his offer to settle and sued Still for damages arising from the accident. MetLife then attempted to accept Jameson's original settlement offer. The circuit court granted summary judgment for Still, concluding that MetLife's counteroffer did not terminate the settlement offer and that its subsequent letter of acceptance created a settlement agreement between the two parties. The Supreme Court vacated the judgment, holding that that the circuit court erred in granting summary judgment on the basis of settlement because no settlement agreement was reached. View "Jameson v. Still" on Justia Law

The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission reversing the administrative law judge's (ALJ) award of permanent and total disability (PTD) benefits against the Second Injury Fund, holding that the Commission's findings were supported by substantial and competent evidence.Christopher Klecka suffered a compensable work-related injury to his left shoulder. After settling the primary claim with his employer Klecka brought a claim against the Fund, alleging that his primary injury combined with his prior injuries rendered him permanently and totally disabled (PTD). An ALJ issued an award against the fund for PTD benefits. The Commission reversed. The Supreme Court affirmed, holding that Klecka failed to establish that his primary injury and sole qualifying preexisting disability entitled him to PTD benefits from the Fund under Mo. Rev. Stat. 287.220.3. View "Klecka v. Treasurer of Missouri" on Justia Law

The Supreme Court dismissed this appeal from the decision of the Labor and Industrial Relations Commission (Commission) reversing the administrative law judge's award and denying Claimant permanent total disability benefits, holding that Claimant's brief preserved nothing for appellate review because it failed to comply with the mandatory and straightforward rules governing the contents of an appellant's briefs.After the Commission denied Claimant's claim, Claimant appealed. The Supreme Court dismissed the appeal, holding that each of Claimant's points on appeal was defective because each point relied on wholly failed to follow the simple template provided in Rule 84.04. View "Lexow v. Boeing Co." on Justia Law