Justia Missouri Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court in favor of Meyer Electric Company on John Lisle's claim that Meyer Electric violated Mo. Rev. Stat. 287.780 by refusing to hire him because he exercised his chapter 287 rights during his prior employment relationship with the company, holding that there was no error.On appeal, Lisle argued that the circuit court misapplied the provisions of section 287.780 by requiring him to establish that he was an "employee" at the time Meyer Electric discriminated against him for exercising his workers' compensation rights. The Supreme Court disagreed, holding (1) as strictly construed, section 287.780 gives an employee a civil action for damages against his or her employer for discharging or discriminating against the employee while employed because the employee exercised a right established under chapter 287; and (2) because it was an uncontroverted material fact that Lisle was not an employee of Meyer Electric when it refused to hire him, Meyer Electric established its right to judgment, as a matter of law. View "Lisle v. Meyer Electric Co., Inc." on Justia Law

The Supreme Court issued a writ prohibiting the Honorable Steven A. Judge Privette from proceeding in the underlying proceeding initiated against Betty Grooms, the circuit clerk of Oregon County, for contempt of court, holding that Judge Privette lacked authority to hold Grooms in contempt for alleged deficiencies in complying with the court order at issue.The subject court order directed Groom to prepare a spreadsheet of court costs assessed in criminal cases after local sheriff departments alleged that they had not received reimbursement for costs incurred incarcerating individuals in their county jails. Judge Privette subsequently ordered Grooms to show cause why she should not be held in contempt of court. The Supreme Court granted a writ of prohibition requested by Grooms, holding that Judge Privette lacked authority to hold Grooms in contempt for her alleged deficiencies in complying with the court order. View "State ex rel. Grooms v. Honorable Privette" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of one count of kidnapping in the first degree and one count of committing violence against an employee of the Department of Corrections, holding that there was no plain error in the proceedings below.On appeal, Defendant argued that the circuit court erred in failing to conduct a sufficient Faretta hearing to ensure his waiver of counsel was knowing, intelligent, and voluntary and in ordering his sentence to consecutively to his prior sentence, in violation of his plea agreement with the State. The Supreme Court affirmed, holding (1) Defendant failed to demonstrate that the circuit court plainly erred in sustaining Defendant's request to represent himself; and (2) the circuit court did not err in ordering Defendant's sentences to run consecutively. View "State v. Teter" on Justia Law

The Supreme Court affirmed the decision of the administrative hearing commission (AHC) finding that Charter Communications Entertainment I, LLC (CCE I) was entitled to manufacturing exemptions with respect to its 2011 and 2012 purchases of replacement equipment used to provide telecommunications service, holding that the AHC's decision was authorized by law.Specifically, the Supreme Court held that the AHC did not err in (1) finding CCE I's provision of telecommunications service qualified as "manufacturing" for purposes of the sales and use tax exemptions in Mo. Rev. Stat. 144.030.2(4) and 144.054.2; and (2) finding that CCE I was not required to establish that its replacement equipment was "substantially used" in manufacturing in addition to proving that the equipment satisfied the integrated plant doctrine and was "used directly" in manufacturing. View "Charter Communications Entertainment I, LLC v. Director of Revenue" on Justia Law

In 1995, MacColl, charged with having “deviate sexual intercourse with an unnamed juvenile female,” pleaded guilty to sexual misconduct, a class A misdemeanor. The circuit court sentenced MacColl to one year in jail, suspended the execution of her sentence, and placed her on two years’ probation. MacColl completed required sexual offender treatment programs; the circuit court discharged MacColl from probation in 1997.In 2000, Boone County sheriff’s office personnel advised MacColl to register as a sexual offender under the Missouri Sex Offender Registration Act (MO-SORA) MacColl registered as a sex offender and has maintained her registration. In 2020, MacColl sought removal from the registry, arguing that she does not have a prior or current independent obligation to register under the Sex Offender Registration and Notification Act, 34 U.S.C. 20901 (SORNA) The circuit court found MacColl was required to register in 1995 because the offense to which she pleaded guilty was a sex offense against a minor as defined by the federal Jacob Wetterling Act (SORNA's predecessor); MacColl was required to register under MO-SORA beginning in 2000 because she was someone who has been required to register under federal law.The Missouri Supreme Court reversed. A genuine issue of material fact exists regarding whether the sex offender treatment programs MacColl completed during her probation qualified as a program certified by a jurisdiction or the attorney general to entitle her to a reduction in her registration period, which would resolve whether MacColl ever was required to register. View "MacColl v. Missouri State Highway Patrol" on Justia Law

The Supreme Court vacated the judgment of the circuit court denying Defendant's pro se motion for postconviction relief filed under Mo. R. Crim. P. 24.035, holding that remand was required for the motion court to make a factual finding so it may determine whether Defendant's pro se motion was timely filed.Defendant pleaded guilty to two charges of driving while intoxicated, one in Laclede County and one in Dallas County. No written judgment was entered in the Dallas County case until when Defendant was found to have violated the probation conditions in that case. Defendant's sentence in the Dallas County case was then executed. Thereafter, Defendant filed his pro se motion for postconviction relief, which the motion court denied. The court of appeals remanded the case. Before the Supreme Court the State argued that Defendant's case must be dismissed because his original pro se motion was filed out of time. The Supreme Court remanded the case, holding that a factual finding was required as to when Defendant was first delivered to the Department of Corrections on the Dallas County case so it may be determined on the basis of that fact whether Defendant's postconviction motion was timely filed. View "Hatmon v. State" 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 vacated the judgment of the circuit court dissolving a permanent injunction placing restrictions on Glendale Shooting Club, Inc.'s firing range operations, holding that the circuit court erred in entering summary judgment.In 1987, the circuit court entered injunctive relief limiting operation of the firing range. In 1988, the General Assembly enacted Mo. Rev. Stat. 537.294, which prohibited courts from enjoining the use or operating of firearm ranges on the basis of noise or sound emission. In 1998, Glendale moved to dissolve the permanent injunction. The circuit court dismissed the motion. The court of appeals reversed and remanded the case for the circuit court to consider the effect of section 537.294 on the enforcement of the injunction. Following remand, Glendale entered into a settlement agreement precluding further litigation over the injunction for twenty years. After the twenty-year period expired, Glendale filed another petition to dissolve the permanent injunction pursuant to section 537.294. The circuit court granted summary judgment for Glendale. The Supreme Court vacated the judgment below, holding that summary judgment was improper because Glenadale did not assert uncontroverted material facts demonstrating that the change in law rendered the continued enforcement of the injunction inequitable. View "Glendale Shooting Club, Inc. v. Landolt" on Justia Law

The Supreme Court affirmed the judgment of the circuit court finding Defendant guilty of two counts of first-degree statutory sodomy and one count of first-degree child molestation, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued, among other things, that the circuit court committed plain error by proceeding to a bench trial without obtaining a sufficient waiver of his constitutional right to a jury trial. The Supreme Court affirmed, holding (1) Defendant's waiver of his right to a jury trial was constitutionally sufficient; and (2) the circuit court did not plainly err by admitting a video recording of the victim's forensic interview pursuant to Mo. Rev. Stat. 492.304. View "State v. Hilbert" on Justia Law

The Supreme Court dismissed this appeal brought by A.S. and A.S. (together, Relatives) challenging the decision of the trial court to overrule their motion for a new trial following an adjudication hearing on the juvenile officer's neglect petition under Mo. Rev. Stat. 211.031, holding that Relatives lacked standing to appeal.After Child's motion consented to the termination of her parental rights, Relatives filed a petition seeking transfer of custody and adoption of Child. The court granted Relatives temporary custody. Later, the juvenile officer filed a petition alleging that the persons legally responsible for Child's care refused to provide the proper support necessary for Child's well being. After the court ordered that Child be placed in the temporary protective custody of the Children's Division the court found the facts set forth in the neglect petition were established by clear and convincing evidence and committed Child to the custody of the Children's Division for appropriate placement. Relatives appealed. The Supreme Court dismissed the appeal, holding that Relatives had no statutory right to appeal. View "In re L.N.G.S." on Justia Law