Justia Missouri Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court, holding that the Missouri Constitution does not permit the General Assembly to limit the Conservation Commission's authority to expend and use conservation funds for constitutionally-enumerated purposes.The General Assembly enacted House Bill No. 2019 in 2020, appropriating $21 million to the Conservation Commission. The General Assembly, however, removed language from HB 2019 regarding use of the Commission's funds, including for land acquisition and payments in lieu of taxes (PILT). Later, the Commission attempted to withdraw funds to pay for a land acquisition and for PILT, but the Office of Administration denied the requests. The Commission and the Missouri Department of Conservation brought this action against the Attorney General and the Commissioner of the Office of Administration seeking declaratory relief to require certification of PILT payments. The circuit court ordered the Commissioner to certify the land purchase and PILT payments as requested. The Supreme Court affirmed, holding that, in passing HB 2019, the General Assembly invaded the Commission's constitutional authority by attempting to limit the constitutionally-enumerated purposes for which the Commission could use its funds. View "Conservation Comm'n v. Bailey" on Justia Law

The Supreme Court affirmed Defendant's conviction for first-degree statutory sodomy, incest, first-degree child molestation, and one count of first-degree attempted rape, holding that the circuit court's jury instructions did not violate Defendant's constitutional right to a unanimous verdict.On appeal, Defendant argued that the evidence presented at trial included multiple allegations of abuse related to each count of sexual misconduct and that five separate verdict directors violated his constitutional right to a unanimous jury verdict. The Supreme Court affirmed, holding that the jury instructions violated Defendant's right to a unanimous verdict. View "State v. Hamby" on Justia Law

The Supreme Court affirmed the order of the circuit court overruling Appellants' motion to vacate the court's order appointing a receiver for Appellants, holding that the petition filed by Patriots Bank seeking the appointment of a receiver pursuant to the Missouri Commercial Receivership Act (MCRA), Mo. Rev. Stat. 515.500-515.665, did not violate due process.Bank entered into lending relationships with Appellants, all of which defaulted. Bank filed a petition seeking the appointment of a receiver for Appellants. The circuit court entered the receiver order. The Supreme Court affirmed, holding (1) the Bank complied with the plain language of the MCRA's notice requirement; (2) the application of the MCRA to Appellants' case did not violate the due process protections under either the state or federal constitutions; (3) the circuit court did not abuse its discretion in overruling Appellants' motion to vacate the receiver order; and (4) the receiver order did not violate the MCRA. View "Black River Motel, LLC v. Patriots Bank" on Justia Law

The Supreme Court affirmed the judgment of the circuit court affirming the decision of the director of revenue to suspend Defendant's driver's license pursuant to Mo. Stat. 302.505, holding that the circuit court did not err in admitting testimony that a preliminary breath test was greater than 0.08 percent or in finding that Defendant was arrested upon probable cause for an alcohol-related offense.Specifically, the Supreme Court held (1) the result of a preliminary breath test is a numerical percentage by weight of alcohol in the blood of the test person, and section 577.021.3 allows a court to admit the result as evidence of probable cause to arrest; (2) because the numerical result in this case was known to the arresting officer at the time of arrest the circuit court was allowed to consider it in determining that the officer had probable cause to arrest Defendant; and (3) the judgment was supported by substantial evidence and was not against the weight of the evidence. View "Wilmoth v. Director of Revenue" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of possessing a controlled substance, in violation of Mo. Rev. Stat. 579.015.1, and unlawfully using a weapon while in possession of a controlled substance, in violation of Mo. Rev. Stat. 571.030.1, holding that Defendant's convictions did not infringe upon his right to be free from double jeopardy.On appeal, Defendant argued that his convictions violated double jeopardy protections because they arose from the same conduct. The Supreme Court reversed, holding that no double jeopardy violation existed because the plain language of the states combined with fundamental principles of statutory interpretation clearly demonstrated the legislature's intent to authorize multiple punishments under sections 579.015 and 571.030.1(11). View "State v. Onyejiaka" on Justia Law

The Supreme Court dismissed Juvenile's appeal of his delinquency adjudication, holding that Juvenile's appeal of the issue of whether he "knowingly and voluntarily" admitted to the conduct alleged in the juvenile officer's amended petition was untimely.The juvenile officer filed an amended petition alleging that Juvenile committed second-degree burglary, first-degree trespass, and two counts of second-degree property damage. After a restitution hearing, the juvenile division set restitution at $4,000. Juvenile appealed, seeking review of the adjudication hearing and order of disposition. The Supreme Court dismissed Juvenile's appeal, holding that the appeal was untimely. View "P.D.E. v. Juvenile Officer" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of three counts of child molestation in the first degree and three counts of statutory sodomy in the first degree, holding that Defendant was not entitled to relief on his allegations of error.In this case, the Supreme Court was required sua sponte to determine whether Defendant's appeal was timely, whether a written judgment of conviction in the proper form had been entered of record, and whether the Court was stripped of appellate jurisdiction. The Supreme Court held (1) this Court had jurisdiction of Defendant's appeal; (2) Defendant did not establish a right to a new trial on the basis of newly discovered evidence; and (3) the circuit court did not plainly error in failing sua sponte to exclude certain testimony. View "State v. Vandergrift" on Justia Law

The Supreme Court denied Petitioner's petition seeking a writ prohibiting his execution and to appoint a special master to conduct an evidentiary hearing on his incompetency claim, holding that Petitioner did not demonstrate the required "substantial threshold showing of insanity" and that his mental illness claims were procedurally barred.On April 19, 2023, the Supreme Court issued a warrant for Petitioner's execution. One month later, Petitioner filed a petition for a writ of habeas corpus claiming that his execution would violate the Eighth and Fourteenth Amendments because he was incompetent to be executed under the standard set forth in Panetti v. Quarterman, 551 U.S. 930 (2007), and Ford v. Wainwright, 477 U.S. 399 (1986), and because he was severely mentally ill. Petitioner asked the Supreme Court to issue a writ prohibiting his execution and to appoint a special master to conduct an evidentiary hearing on his incompetency claim and filed a motion for a stay of execution while his incompetency claim was adjudicated. The Supreme Court denied Petitioner's habeas petition and overruled as moot his accompanying motion for a stay of execution, holding that Petitioner did not demonstrate the substantial threshold showing of insanity required by Panetti and Ford. View "State ex rel. Johnson v. Vandergriff" on Justia Law

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