Justia Missouri Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgments of the circuit court denying Appellants' petitions for removal from the Missouri sex offender registry, holding that the circuit court did not err.Appellants Brock Smith and Gary Ford separately appealed two circuit court judgments denying their separately-filed petitions for removal from the Missouri sex offender registry. Smith argued that because he was a tier I sex offender, Mo. Rev. Stat. 589.400.1(7) did not mandate that he remain on the registry for his lifetime. Ford argued that the lower court misstated and misapplied the law in denying his petition. The Supreme Court affirmed in both cases, holding that the circuit court did not err in concluding that Appellants were not entitled to removal from the Missouri sex offender registry. View "Smith v. St. Louis County Police" 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 affirmed the decision of the Labor and Industrial Relations Commission denying Appellant's claim for benefits from the Second Injury Fund, holding that the Commission did not abuse its discretion and that the Commission's findings were supported by substantial evidence.On appeal, Appellant challenged the Commission's decision to overrule his motion to conduct additional discovery and submit additional evidence after the Supreme Court's decision in Cosby v. Treasurer of Missouri, 579 S.W.3d 202 (Mo. banc 2019) interpreting Mo. Rev. Stat. 287.220 and the Commission's finding that Appellant failed to show any medically documented qualifying preexisting disabilities that qualified him for benefits. The Supreme Court affirmed, holding (1) the Commission did not abuse its discretion in overruling Appellant's motion to conduct additional discovery and submit additional evidence; and (2) the Commission's findings were supported by substantial and competent evidence. View "Dubuc v. Treasurer of State of Missouri Custodian of Second Injury Fund" on Justia Law

The Supreme Court vacated the judgment of the circuit court confirming M.O.'s arbitration award in this personal injury action, holding that the circuit court erred in confirming the arbitration award because GEICO General Insurance Company was statutorily entitled to intervene in the pending lawsuit between M.O. and M.B. pursuant to Mo. Rev. Stat. 537.065.2.M.O. sued M.B. alleging that she had contracted HPV from M.B. while having sexual relations in M.B.'s vehicle, which was insured by GEICO. had sexual relations in M.B.'s vehicle, which was insured by GEICO. M.B. and M.O., without informing GEICO, entered into an agreement providing that M.O.'s claims were be submitted to arbitration but that M.O. would seek recovery of any judgment from M.B.'s insurers. The arbitrator awarded M.O. $5.2 million. M.O. then sued M.B. without informing GEICO. After GEICO filed its motion to intervene the circuit court confirmed the arbitration award. Thereafter, the circuit court sustained GEICO's motion to intervene. The Supreme Court vacated the circuit court's judgment, holding that GEICO was statutorily entitled to intervene in the underlying lawsuit before judgment was entered. View "M.O. v. GEICO General Insurance Co." on Justia Law