Justia Missouri Supreme Court Opinion Summaries

The Supreme Court vacated the order of the circuit court entering a declaratory judgment that Mo. Rev. Stat. 115.646 violated public officials' right to free speech and was void for vagueness, holding that the circuit court erred.Section 115.646 prohibits officials from directly using public funds to advocate, support, or oppose a ballot measure or candidate for public office. Plaintiffs initiated a lawsuit seeking a judgment declaring section 115.646 unconstitutional. The circuit court sustained Plaintiffs' motion for summary judgment, declaring that section 115.646 violated the officials' First Amendment rights. The Supreme Court vacated the judgment, holding (1) because section 115.646 regulates the use of public funds, not the officials' speech, it does not implicate the free speech clause of the First Amendment; and (2) the circuit court erred in declaring certain words and phrases in the statute to be unconstitutionally vague. View "City of Maryland Heights v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court issuing a declaratory judgment invalidating Mo. Rev. Stat. 116.180 and 116.334.2, which prohibit the collection of referendum petition signatures before the Secretary of State has certified the referendum's official ballot title and affixed it to the petition, holding that there was no error.In invalidating sections 116.180 and 116.334.2, the circuit court declared that those provisions interfere with and impede the right of referendum, therefore conflicting with Mo. Const. art. III, 49 and 52(a). The Supreme Court affirmed the judgment declaring those statutes constitutionally invalid, holding that the statutes' prohibition on collecting referendum petition signatures before the Secretary certifies the official ballot title unreasonably shores the timeframe for petition circulation, thus interfering with and impeding the constitutional right of referendum reserved to the people. View "No Bans on Choice v. Ashcroft" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying the petition for a permanent writ of prohibition filed by the Missouri Department of Health and Senior Services, holding that the circuit court did not err in denying the writ.After the Department denied the applications filed by Kings Garden Midwest LLC seeking two medical marijuana cultivation facility licenses Kings Garden requested that the Department provide complete and unreacted copies of successful cultivation license applications in discovery. The administrative hearing commission (AHC) granted the motion to compel. The Department filed a petition for a writ of prohibition seeking to bar enforcement of the AHC's order. The circuit court denied the writ. The Supreme Court affirmed, holding that because the plain language of allows confidential information to be used for purposes of appealing the Department's decision to deny a license, the AHC did not err in sustaining Kings Garden's motion to compel. View "State ex rel. Department of Health & Senior Services v. Slusher" on Justia Law

The Supreme Court affirmed the decision of the Judicial Finance Commission (JFC) dismissing the Board of Commissioners of Franklin County's petition for review disputing whether the statutory maintenance of effort (MOE) operated as a statutory cap on its obligation to fund the Twentieth Judicial Circuit Court's Juvenile Division, holding that there was no error.When the Franklin County Commission and a judge of the Twentieth Circuit met to discuss the 2021 budget, the parties could not agree whether Franklin County would provide only the statutorily required MOE funding for the Juvenile Division. The Commission filed a petition for review with the JFC seeking a declaration that it would be not compelled to allocate and pay more than the MOE funding for the Juvenile Division. The JFC dismissed the action. The Supreme Court affirmed, holding that the JFC did not err in dismissing the Commission's petition for review. View "Board of Commissioners of County of Franklin v. Twentieth Judicial Circuit" on Justia Law

The Supreme Court denied the writ of prohibition sought by T.J. to dismiss the state's prosecution against him without prejudice so that the circuit court's juvenile division may adjudicate the charges against him, holding that T.J. was not entitled to the writ.The State charged T.J. in the court of general jurisdiction with committing three felony offenses when he was seventeen years old. T.J. filed a motion to dismiss, contending that the juvenile division had the exclusive authority to adjudicate the charges against him pursuant to legislation enacted in 2018. The circuit court overruled the motion. The Supreme Court affirmed, holding that the juvenile division did not have the statutory authority to adjudicate the charged offenses. View "State ex rel. T.J., v. Honorable Cundiff" on Justia Law

The Supreme Court reversed the judgment of the circuit court dismissing without prejudice the state's prosecution against R.J.G., who was alleged to have committed several felony offenses when he was seventeen years old, holding that the circuit court erred in dismissing the state's prosecution in the court of general jurisdiction.The state charged R.J.G. with felony offenses in a court of general jurisdiction. R.J.G. filed a motion to dismiss on the grounds that the circuit court's juvenile division had the exclusive statutory authority to adjudicate the charges pursuant to legislation enacted in 2018. The circuit court agreed and sustained the motion. The Supreme Court reversed, holding (1) the law as it existed at the time R.J.G. was alleged to have committed the offenses governed which division had the authority to adjudicate the offenses; and (2) the juvenile division did not have the statutory to adjudicate the offenses in this case, and therefore, the circuit court erred in dismissing the state's prosecution in the court of general jurisdiction. View "State v. R.J.G." on Justia Law

The Supreme Court reversed the circuit court's judgment in favor of Danny Brock on his negligence claim against Mark Edwards, holding that the circuit court erred in overruling the motions for directed verdict and judgment notwithstanding the verdict (JNOV) filed by Peter Dunne, defendant ad litem for Edwards.Brock was injured in a work-related accident involving co-worker Edwards. Brock filed a petition alleging a negligence claim against Edwards. Edwards died before trial, and Dunne was substituted as defendant ad litem. The jury returned a verdict in Brock's favor, and the circuit court entered judgment for $873,000 in Brock's favor. The Supreme Court reversed, holding that the circuit court erred in overruling Dunne's motions for directed verdict and JNOV because Edwards was immune from liability pursuant to Mo. Rev. Stat. 287.120.1 and Brock failed to make a submissible case of common law negligence. View "Brock v. Dunne" on Justia Law

The Supreme Court made permanent a preliminary writ of mandamus previously issued by this Court directing the circuit court to vacate its order excluding a digital recording from use at trial for various charges relating to the death of Rebecca Ruud's minor daughter, holding that the circuit court erred.A grand jury returned an indictment against Ruud and her then-husband charging them with first-degree murder, felony abuse or neglect of a child resulting in death, and other crimes. The digital recording at issue was between Ruud and her lawyer's staff and yielded incriminating evidence. The circuit court excluded the digital recording from being admitted at trial, concluding that the attorney-client privilege protected the content of the digital recording. The Supreme Court granted the State mandamus relief, holding that the circuit court abused its discretion in finding that the recording was privileged. View "State ex rel. Garrabrant v. Honorable Holden" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree assault of a law enforcement officer, armed criminal action, and unlawful possession of a firearm by a felon, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued that the circuit court erred in overruling with prejudice his motion to dismiss the first-degree assault and armed criminal action counts and retrying him after a mistrial. Defendant's only specific argument was that the circuit court violated the time limitations for his retrial. The Supreme Court affirmed, holding that the circuit court properly followed the procedure approved in State v. Berry, 298 S.W.2d 429 (Mo. 1957), and therefore, Defendant's retrial did not violate Mo. Const. art. I, 19. View "State v. Shegog" on Justia Law

The Supreme Court affirmed the judgment of the circuit court in favor of Defendants in this personal injury case, holding that there was no error.Arica Linton went into premature labor with her son, Nicholas, and an emergency cesarean section was performed. One year later, Nicholas was diagnosed with a white matter brain injury. Nicholas Linton brought this action against Defendants - healthcare providers - alleging that they failed to timely treat Arica, timely deliver Nicholas, timely perform a cesarean section, and diagnose and treat fetal distress. The jury returned a verdict in favor of Defendants. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in admitting an expert's alternative causation testimony. View "Linton v. Carter" on Justia Law