Justia Missouri Supreme Court Opinion Summaries

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

The Supreme Court reversed a portion of the judgment of the circuit court determining that invalid provisions of parking statutes creating duties for municipal offices could not be severed, holding that the circuit court should have entered and struck provisions of the statutes.Plaintiffs brought this action seeking a judgment declaring the parking statutes at issue in this case, Mo. Rev. Stat. 82.485 and 82.487, were constitutionally invalid because they create powers and duties of municipal offices of a charter city in violation of Mo. Const. art. VI, 22. The circuit court held that the statutes were unconstitutional. The court determined that the constitutionally invalid provisions could not be severed from the remainder of sections 82.485 and 82.487, and therefore, declared the entirety of the parking statues invalid and void. The Supreme Court reversed in part, holding that the circuit court should have entered and struck provisions in sections 82.485 and 82.487 as held in this opinion. View "Wilson v. City of St. Louis" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of first-degree statutory sodomy, three counts of first-degree child molestation, and one count of enticement of a child, holding that Defendant was not entitled to relief on his claims of error.Specifically, the Supreme Court held (1) the circuit court did not abuse its discretion in overruling Defendant's motion to sever count four from counts one through five; (2) the evidence was sufficient to support the convictions; (3) the circuit court did not plainly err in failing sua sponte to declare a mistrial based on testimony the State elicited during Defendant's cross-examination; and (4) the circuit court did not plainly err in failing sua sponte to declare a mistrial based on a comment made by the State during closing argument. View "State v. Boyd" on Justia Law

The Supreme Court granted a preliminary writ of prohibition ordering the circuit court to take no further action in the underlying criminal matter other than dismissing the Washington County prosecuting attorney's motion to vacate or set aside Michael Politte's second-degree murder conviction, holding that the writ was warranted.Politte was convicted in the circuit court of St. Francois County of second degree murder and sentenced to life in prison. The Washington County prosecuting attorney later filed a motion seeking to vacate or set aside Politte's conviction under Mo. Rev. Stat. 547.031. After the attorney general's motion to dismiss was overruled, the attorney general sought a writ prohibiting the circuit court from taking any action other than to dismiss the prosecuting attorney's motion to vacate or set aside Politte's conviction. The Supreme Court issued a writ of prohibition, holding that the motion to vacate or set aside Politte's conviction failed to comply with the requirements of Mo. Rev. Stat. 547.031. View "State ex rel. Bailey v. Honorable Fulton" 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 reversed the judgment of the circuit court reforming a property deed executed by Lillian and J.C. Singleton, as husband and wife, that divested Appellants' interest in the property, holding that the circuit court misapplied the law in reforming the deed.Lillian and J.C,. who were married and had three children, owned two tracts of land - Tract I and Tract II. The couple later instructed their attorney to prepare two warranty deeds, and the attorney did not know or meet with Appellants - Dennis, Keith, or Kelly - when preparing the deeds. After J.C. died, Lillian filed suit against Appellants asking the circuit court either set aside or reform the Tract I deed to reflect her interest that Dennis not receive a remainder interest in that tract, alleging that the deed mistakenly included Dennis in the conveyance. The circuit court entered judgment in Lillian's favor and ordered the Tract I deed to be reformed. The Supreme Court reversed, holding (1) no mutual mistake occurred in this case, and the mistake was purely unilateral; and (2) under the circumstances, the circuit court misapplied long-standing state law when it ordered the deed at issue be reformed to divest Appellants of their remainder interest. View "Singleton v. Singleton" on Justia Law