Justia Missouri Supreme Court Opinion Summaries

The Supreme Court reversed Defendant's conviction for second-degree felony murder and armed criminal action, holding that the circuit court's evidentiary rulings infringed on Defendant's constitutional right to present a complete defense, as guaranteed by the Sixth and Fourteenth Amendments.Defendant's convictions arose from an alleged robbery during which Defendant shot and killed Mathew Haylock. During trial, Defendant attempted to present evidence that he shot Haylock in self-defense after Haylock attempted to rob him. Each time Defendant raise the issue of presenting his own version of events the circuit court denied him the right to provide such evidence. The Supreme Court reversed and remanded the case, holding that by prohibiting Defendant from presenting evidence about the ultimate issue int his case, the circuit court prevented Defendant from presenting a complete defense, in violation of his constitutional rights. View "Missouri v. Gates" on Justia Law

The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission finding that Defendant was not entitled to an award of workers' compensation benefits because his injury did not arise out of and in the course of his employment, holding that there was no error.Defendant, a field service specialist for DISH Network, Inc,. was an a car accident after he choked on a sandwich and blacked out while traveling to his first appointment. Defendant sought workers' compensation benefits. The ALJ awarded benefits, but the Commission denied compensation because Defendant failed to prove his injury arose out of and in the course of his employment. The Supreme Court affirmed, holding that Defendant failed to establish that his injury arose out of and in the course of his employment. View "Boothe v. DISH Network, Inc." on Justia Law

The Supreme Court affirmed certification order of the family court division releasing and discharging J.T.J. from the jurisdiction of the family court and allowing his case to be transferred to a court of general jurisdiction for trial as an adult, holding that there was no error.A juvenile officer filed a petition in the family court alleging that J.T.J., a juvenile, committed second-degree burglary, first-degree property damages, and misdemeanor stealing. The juvenile officer subsequently filed motions to modify alleging more counts and requesting the transfer of jurisdiction of J.T.J. After a certification hearing, the family court ordered J.T.J. transferred to the court of general jurisdiction. On appeal, J.T.J. argued that the family court erred in entering its certification order because the transfer of jurisdiction of a juvenile is not permitted to allow prosecution under the general law upon the filing of a motion to modify. The Supreme Court affirmed, holding that J.T.J. was not prejudiced, and therefore, relief under plain error review was unavailable. View "In re J.T.J." on Justia Law

The Supreme Court affirmed the judgment of the circuit court overruling Defendant's Rule 29.15 motion for postconviction relief without holding an evidentiary hearing, holding that the circuit court did not clearly err in determining that Defendant failed to plead facts not refuted by the record that, if true, resulted in prejudice entitling him to an evidentiary hearing.Defendant was found guilty of four felony sexual offenses. The court of appeals. Defendant subsequently filed a Rule 29.15 motion to vacate, set aside, or correct the judgment, alleging several instances of ineffective assistance of counsel. The circuit court overruled the motion without conducting an evidentiary hearing. The Supreme Court affirmed, holding that the circuit court did not clearly err in denying Defendant's postconviction claims without an evidentiary hearing. View "McLemore v. State" on Justia Law

The Supreme Court made permanent a preliminary writ of prohibition it issued to prevent the release of Darin Lutman's medical records, holding that the circuit court erred in ordering the release of the records because they were protected by the physician-patient privilege.A vehicle driven by Lutman crossed the centerline on a Missouri highway and struck a vehicle driven by Sondra Murrell, who died. Plaintiffs filed a wrongful death suit against Lutman. After Plaintiffs filed notices of depositions and subpoenas for Lutman's medical records with Compass Health Network and Missouri Psychiatric Center, Lutman filed a motion to quash, arguing that the requested information was protected by the physician-patient privilege. The circuit court overruled Lutman's motion to quash. Lutman then filed a petition for a writ of prohibition. The Supreme Court granted the writ, holding that Lutman did not waive the physician-patient privilege and that the circuit court erred in ordering the disclosure of his medical records. View "State ex rel. Lutman v. Honorable Baker" on Justia Law

The Supreme Court vacated in part and affirmed in part the judgment of the circuit court in this case brought by Pamela and Kelly Allen after Pamela fell down a flight of stairs in the Common Pleas Courthouse in Cape Girardeau, holding that the circuit court erred in part.The jury in this case returned verdicts holding the State ninety percent at fault and Pamela ten percent at fault and further found against Kelly on his loss of consortium state. The State appealed and the Allens cross-appealed. The Supreme Court affirmed the circuit court's judgment as to Kelly's loss of consortium claim and otherwise vacated the judgment, holding that the circuit court erred in its interpretation of the phrase "public entity's property" in Mo. Rev. Stat. 537.600.1(2). View "Allen v. State" on Justia Law

The Supreme Court vacated the judgment of the circuit court finding Defendant guilty of voluntary manslaughter and armed criminal action, holding that the circuit court erred in refusing to give a self-defense instruction as requested by Defendant.Defendant was charged with first-degree murder, armed criminal action, and burglary. The jury found Defendant not guilty of burglary but guilty of armed criminal action and the lesser-included crime of voluntary manslaughter. The Supreme Court vacated Defendant's conviction, holding (1) there was substantial evidence to support giving Defendant's proffered self-defense instruction; and (2) the failure to submit this instruction prejudiced Defendant. View "State v. Whitaker" on Justia Law

The Supreme Court vacated the judgment of the circuit court reversing the decision of the Board of Education of the Jefferson City Public School District to terminate Tammy Ferry's contract with the District, holding that the Board had the authority to terminate the contract.The Board decided to terminate Ferry's contract after she transferred confidential student information from the District's Google for Education account to her personal Google account. The circuit court vacated the Board's decision, finding that Ferry had not "disclosed" confidential student information, as that term is defined in the Family Educational Rights and Privacy Act of 1974 (FERA), 20 U.S.C. 1232g. The Supreme Court vacated the circuit court's judgment, holding (1) the Board's findings that Ferry violated the Board's policies and procedure and did so willfully were supported by competent and substantial evidence; and (2) the Teacher Tenure Act authorized the Board to terminate Ferry's indefinite contract with the District. View "Ferry v. Board of Education of Jefferson City Public School District" on Justia Law

The Supreme Court reversed the judgment of the circuit court convicting Defendant of two counts of statutory rape in the second degree, holding that the circuit court erred in permitting witness testimony via two-way live video, in violation of Defendant's right to confrontation under the United States and Missouri Constitutions.Defendant was charged in connections of sexual assault by I.S. At trial, the circuit court allowed the virtual testimony of Erik Hall, a crime laboratory employee who collected a buccal swab from Defendant and completed a DNA analysis and laboratory report. Defendant was found guilty of two count of statutory rape. On appeal, Defendant argued that Hall's two-way live video feed testimony violated his constitutional right to confrontation and due process. The Supreme Court reversed, holding that the circuit court erred in admitting Hall's two-way live video testimony, and the error was not harmless beyond a reasonable doubt. View "State v. Smith" on Justia Law

The Supreme Court vacated the judgment of the circuit court finding that Juvenile committed acts that would constituted first-degree statutory sodomy if committed by an adult, holding that the circuit court erroneously declared and applied the law in admitting two-way video testimony, in violation of Juvenile's right to confrontation.Prior to his adjudication hearing, Juvenile filed an objection to a virtual adjudication and request to appear in person, arguing that he had a constitutional and statutory right to face-to-face confrontation of witnesses against him. The objection was overruled, and the court held the hearing in a "hybrid" format that utilized videoconferencing technology due to the COVID-19 pandemic. After the hearing, the circuit court sustained the allegation of first-degree statutory sodomy beyond a reasonable doubt. The Supreme Court vacated the judgment, holding that the circuit court's general statements concerning COVID-19 did not satisfy the requisite standard for admitting two-way video testimony, in violation of Juvenile's confrontation rights. View "In re C.A.R.A." on Justia Law