Justia Missouri Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court finding that Fredric Prater was liable for $20,000 in damages after a car accident with Denise Kappel, holding that the circuit court did not abuse its discretion in admitting photographs of the rental car Kappel was driving at the time of the accident.Denise was at a stop when Prater drove into her rental car from behind. Denise and her husband (the Kappels) sued Prater for negligence. At trial, the circuit court admitting into evidence, over the Kappels' objection, photographs showing the post-accident damage to the front of his car and the rear of the rental car Denise was driving. The jury found Prater liable for negligence and awarded $20,000 in damages, significantly less than the $650,000 the Kappels sought. The Kappels appealed, arguing that the photographs should not have been admitted because their quality was too low and because there was no expert evidence connecting the amount of damage to Denise's vehicle to the issue of whether the collision caused the injuries she claimed. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in admitting the photographs. View "Kappel v. Prater" on Justia Law

The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission denying Employee's workers' compensation benefits on the grounds that she failed to prove her work injury was the prevailing or primary factor causing any permanent disability and denying Employee's claim against the Second Injury Fund as moot, holding that the Commission did not err.Employee was exposed to cypermethrin, an insecticide, while working for Employer. When Employee was at the doctor's office for testing, another patient's dog got loose and tripped Employee. Employee fell and allegedly sustained permanent injuries to her knees, lower back, hip and neck. Employee filed a claim for workers' compensation asserting that, in addition to cypermethrin exposure, she sustained injuries from being tripped while walking out of the doctor's office. An ALJ awarded Employee benefits. The Commission reversed, concluding that Employee failed to meet her burden of proving her exposure to cypermethrin was the prevailing or primary factor in causing any alleged injury from being tripped accidentally. The Supreme Court affirmed, holding (1) Employee was not entitled to workers' compensation for any injury sustained from her accidental tripping; and (2) because Employee's accidental tripping did not arise out of and in the course of her employment, the Fund was not implicated. View "Schoen v. Mid-Missouri Mental Health Center" on Justia Law

The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission denying Appellant's claim for workers' compensation benefits for injuries she suffered when she fell while entering her workplace, holding that Appellant failed to prove that her injury arose out of and in the course of her employment.An administrative law judge denied Appellant any workers' compensation benefits, concluding that Appellant did not meet her burden of showing that her fall was the prevailing factor causing the conditions of which she complained. The Commission affirmed, holding that Appellant failed to establish that her injury arose out of her employment. The Supreme Court affirmed, holding that Appellant's claim was noncompensable because she failed to prove her injury arose out of and in the course of her employment because the hazard or risk involved was one Appellant was equally exposed to in her regular, nonemployment life. View "Annayeva v. SAB of the TSD of the City of St. Louis" on Justia Law

The Supreme Court affirmed the decision of the labor and industrial relations commission denying Claimants' claim for enhanced mesothelioma benefits under Mo. Rev. Stat. 287.200.4(3)(a), holding that because the deceased employee's employer (Employer) did not "elect to accept mesothelioma liability," Claimants were not entitled to the enhanced benefit.The decedent died from mesothelioma cause by toxic exposure to asbestos during his employment with Employer. Prior to his death, Claimants filed a claim for workers' compensation benefits and specifically sought enhanced benefits under subdivision 287.200.4(3)(a). An administrative law judge denied the claim. The commission affirmed the denial of the enhanced benefit, concluding that an employer that ceased operations sixteen years before section 287.200.4(3)(a) took effect could not have elected to accept enhanced liability under that section. The Supreme Court affirmed, holding that Claimants were not entitled to the enhanced benefit because Employer did not affirmatively elect to accept liability for the enhanced benefit as required under statute. View "Hegger v. Valley Farm Dairy Co." on Justia Law

The Supreme Court reversed the judgment of the circuit court finding in favor of Plaintiffs on their negligent credentialing claim against Defendant, St. Luke's Surgicenter-Lee's Summit LLC, holding that Plaintiffs failed to make a submissible case of negligent credentialing.In their complaint, Plaintiffs alleged that Defendant negligently granted a surgeon operating out of St. Luke's Surgicenter in Lee's Summit staff privileges at its hospital. After a jury trial, the circuit court entered judgment in favor of Plaintiffs. The Supreme Court reversed the judgment of the trial court and remanded the case for a new trial, holding that the circuit court erred in overruling Defendant's motion for judgment notwithstanding the verdict because Plaintiffs failed to make a submissible case of negligent credentialing. View "Tharp v. St. Luke's Surgicenter-Lee's Summit, LLC" on Justia Law

The Supreme Court affirmed the judgments of the circuit court granting summary judgment for Respondents and dismissing Appellants' five separate actions for fraudulent concealment, holding that Appellants' claims for fraudulent concealment were barred by Mo. Rev. Stat. 516.120(5).In 2010 and 2011, Appellants filed five separate, but similar, wrongful death lawsuits against Respondents. The circuit court dismissed the wrongful death suits. In 2016, Appellants filed five separate, but almost identical, petitions alleging fraudulent concealment by Respondents, alleging that Respondents damaged Appellants by causing them to lose their right to timely file wrongful death causes of action. The circuit court found Appellants claims were barred both by the doctrine of res judicata and by the five-year statute of limitations for fraud claims set forth in Mo. Rev Stat. 516.120(5). The Supreme Court affirmed, holding that Appellants' claims were barred by section 516.120(5). View "Boland v. Saint Luke's Health System" on Justia Law

The Supreme Court made permanent a preliminary writ of prohibition it issued barring the circuit court from taking any further action other than to vacate an order overruling Relator's motion for summary judgment and to enter judgment for Relator, holding that Relator was entitled to official immunity.Israel Mariano, a student at Independence Academy, filed a negligence suit against Relator, an in-school suspension teacher, in his individual capacity for injuries Mariano sustained when Relator physically restrained him and broke his arm. The circuit court overruled Relator's motion summary judgment claiming he was entitled to official immunity. Relator sought a writ of prohibition. The Supreme Court granted the writ, holding that Relator was entitled to official immunity under the circumstances of this case. View "State ex rel. Alsup v. Honorable James F. Kanatzar" on Justia Law

The Supreme Court reversed the order of the circuit court overruling Appellant's motion to dismiss and compel arbitration, holding that Mo. Rev. Stat. 435.355 obligated the circuit court to order the parties to proceed to arbitration under the circumstances of this case.Prior to his discharge from the hospital, Theron Ingram executed a written Durable Power of Attorney naming Andrea Nicole Hall as his attorney in fact. Ingram was subsequently admitted to Brook Chateau, and Hall executed an arbitration agreement with Brook Chateau on Ingram's behalf. Ingram later filed a petition against Brook Chateau alleging negligence and seeking punitive damages. Brook Chateau responded by filing a motion to dismiss and compel arbitration. The circuit court overruled the motion, and the court of appeals affirmed. The Supreme Court reversed, holding that the circuit court was required under section 435.355 to compel arbitration because Brook Chateau attached a valid arbitration agreement alongside its motion to dismiss and compel arbitration. View "Ingram v. Chateau" on Justia Law

The Supreme Court affirmed the judgment of the circuit court overruling Appellant's Rule 75.06(b) motion to set aside the dismissal of a wrongful death suit filed by his deceased son's grandmother and the overruling of his motion to intervene in that suit, holding that Appellant never became a party to the grandmother's suit and that there was no judgment to be set aside.The grandmother filed a petition alleging wrongful death after the police shot and killed Appellant's son. Appellant sought to join the grandmother's suit, but the motion failed to comply with the requirements of Rule 52.12(c). The grandmother later dismissed her lawsuit. Appellant later filed his motion to set aside the judgment and to intervene in that suit. The circuit court overruled the motion. The Supreme Court affirmed, holding (1) because Appellant failed to comply with Rule 52.12 governing intervention and his motion was never ruled on prior to the grandmother's voluntary dismissal of her suit, Appellant never became a part to the grandmother's suit; and (2) there was no judgment to be set aside because the grandmother voluntarily dismissed her suit, and that dismissal took effect immediately upon filing. View "Henry v. Piatchek" on Justia Law

The Supreme Court made permanent a preliminary writ of prohibition it issued directing the circuit court to dismiss Plaintiff's claims against Relators for lack of personal jurisdiction, holding that Plaintiff failed to show that Relators were "at home" in Missouri and failed to identify any conduct by Relators in Missouri out of which Plaintiff's claims arose.Plaintiff filed suit against Relators, Kansas business entities, alleging personal injury sustained while working at an apartment complex in Kansas. Relators sought a writ of prohibition on the ground that the circuit court lacked personal jurisdiction over them. The court of appeals overruled the motion. Relators then petitioned the Supreme Court for the same relief. The Supreme Court granted relief, holding (1) Relators were not "at home" in Missouri to such an extent that they were subject to the general jurisdiction of Missouri courts; and (2) Relators' contacts with Missouri were not sufficient to create general or specific jurisdiction on their own. View "State ex rel. Cedar Crest Apartments, LLC v. Honorable Jack Grate" on Justia Law