Justia Missouri Supreme Court Opinion Summaries

The Supreme Court vacated the judgment of the circuit court finding that J.A.T. committed acts that would constitute first-degree assault and armed criminal action if committed by an adult, holding that requiring J.A.T. to attend the adjudication hearing via two-way live video violated his constitutional rights to due process and confrontation.While J.A.T. repeatedly asserted his right to be physically present at his adjudication hearing to defend himself, the circuit court required J.A.T. to attend his adjudication hearing via two-way video to limit the exposure of germs during the COVID-19 pandemic. The Supreme Court vacated the circuit court's judgment, holding (1) generalized concerns about the COVID-19 virus may not override a juvenile's due process right to be physically present for his juvenile adjudication hearing at which his guilt or innocence will be determined; and (2) the circuit court erred in requiring J.A.T.'s attendance and participation via two-way video, in violation of J.A.T.'s due process right to be physically present at his adjudication hearing. View "In re J.A.T." on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the circuit court dismissing Petitioner's petition for declaratory judgment for failure to state a claim upon which relief can be granted, holding that the circuit court improperly dismissed Petitioner's claim with prejudice.In his petition, Petitioner sought a declaration that his federal supplemental security income was exempt under federal law from paying the required monthly intervention fees to the Missouri Department of Corrections, Division of Probation and Parole, as a condition of his supervised probation. The circuit court dismissed the petition with prejudice. The Supreme Court reversed in part, holding (1) Petitioner's request for declaratory relief was not ripe for adjudication; but (2) because Petitioner may be able to state a claim ripe for adjudication in the future, the circuit court improperly dismissed the claim with prejudice. View "Graves v. Missouri Department of Corrections" on Justia Law

The Supreme Court affirmed the judgment declaring that the Honorable Patrick S. Flynn did not have authority, as the presiding judge of the 45th Judicial Circuit, to suspend Karla Allsberry, the circuit clerk of Lincoln County within the 45th Judicial Circuit, holding that the circuit court erred.At issue was whether Judge Flynn had the power under his general administrative authority as the presiding judge to suspend Allsberry, an elected circuit clerk, when the suspension was indefinite and had the effect of removing her from office, and whether the court had the authority to grant Allsberry injunctive relief. The Supreme Court held (1) the presiding judge is not authorized to take any action that has the practical effect of removing an elected circuit clerk from office; and (2) the circuit court erred in concluding that one circuit judge cannot order injunctive relief against another circuit judge. View "Allsberry v. Flynn" on Justia Law

The Supreme Court affirmed the order of the circuit court sustaining Defendant's motion to suppress a cell phone and electronic data stored on that cell phone, holding that the circuit court did not err in sustaining the motion to suppress.The circuit court concluded that the search warrant failed to describe with sufficient particularity the thing to be seized and was so facially deficient that the executing officers could not reasonably have presumed it to be valid. The Supreme Court affirmed, holding (1) the seizure of a cell phone at the sheriff's office was outside the scope of the warrant, so the evidence was not validly seized; and (2) the officer conducting the search did not have a good faith basis when he executed the search warrant at the sheriff's office, contrary to the clear directions of the search warrant to search a cell phone located at a particular address. View "State v. Bales" on Justia Law

The Supreme Court denied Defendant's petition for a writ of habeas corpus, holding that Defendant was eligible for the death penalty because he failed to prove that he was intellectually disabled, and Defendant was not entitled to relief on any of his remaining claims.Defendant was found guilty of three counts of first-degree murder and sentenced to three death sentences. After the Supreme Court issued an order setting Defendant's execution date Defendant filed this petition for writ of habeas corpus, raising three allegations. The Supreme Court affirmed, holding (1) Defendant was not intellectually disabled and was therefore eligible for the death penalty; (2) the jury instructions on intellectual disability did not violate Defendant's constitutional rights; and (3) Defendant's method of execution claim failed. View "State ex rel. Johnson v. Blair" on Justia Law

The Supreme Court vacated the circuit court's judgment on the pleadings dismissing Wife's Rule 74.06(b) motion to set aside, for fraud, the judgment of dissolution of her marriage to Husband or, alternatively, the property division portion of the judgment, holding that the circuit court erred.Before the circuit court ruled on Wife's Rule 74.06(b) motion Husband died, and the personal representative of his estate was substituted as the respondent. The circuit court sustained the personal representative's motion for judgment on the pleadings, finding that Wife's Rule 74.06(b) motion was moot because (1) Husband's death abated and rendered the motion moot, and (2) the relief sought in the motion could not be granted. The Supreme Court vacated the judgment, holding that the circuit court erred in (1) finding that Husband's death abated the proceedings on Wife's Rule 74.06(b) motion; and (2) finding that meaningful relief was unavailable under Rule 74.06(b). View "Olofson v. Olofson" on Justia Law

The Supreme Court vacated the judgment of the circuit court granting summary judgment in favor of the Defendants and dismissing Plaintiffs' action seeking a declaratory judgment that Mo. Rev. Stat. 321.320 is an unconstitutional special law and that House Bill No. 1446 (HB 1446) violates the single-subject provision of the Missouri Constitution, holding that the circuit court erred.The City of De Soto and James Acres brought this action against the governor and the attorney general challenging section 321.320 and HB 1446. The De Soto Fire Protection District intervened as a defendant. The circuit court entered judgment for Defendants. The Supreme Court vacated the judgment below, holding that HB 1446 violates the prohibition against multiple subjects in Mo. Const. art. III, 23 and that the entire bill is invalid and may not be enforced. View "City of De Soto v. Parson" on Justia Law

The Supreme Court affirmed the circuit court's reduction of a damages award in favor of Appellant in a medical negligence case against University Physician Associates (UPA) and various physicians (collectively, the Physicians), holding that the circuit court did not err.Appellant filed this lawsuit alleging that the Physicians acted negligently in the Caesarean delivery of her child and in her postpartum care. The jury allocated 100 percent of fault to the Physicians and awarded $30,000 in past economic damages, $300,000 in past non-economic damages, and $700,000 in future non-economic damages. The circuit court concluded that Mo. Rev. Stat. 538.210.2(2)'s non-economic damages for catastrophic personal injury applied and reduced the non-economic damages award from $1 million to $748,828. The Supreme Court affirmed, holding (1) section 538.210's non-economic damage caps do not violate Mo. Const. art. I, 22(a); and (2) the Physicians' points on appeal lacked merit. View "Ordinola Velazquez v. University Physician Associates" on Justia Law

The Supreme Court affirmed in part and vacated in part the judgment of the circuit court rejecting Plaintiffs' claims challenging the refusal by the Department of Social Services (DSS) to provide MO HealthNet coverage, holding that the circuit court erred in declaring Mo. Const. art. IV, 36(c) constitutionally invalid.Plaintiffs, three Missourians eligible for MO HealthNet coverage under article IV, section 36(c), brought this action challenging the DSS's refusal to provide coverage on the grounds that the General Assembly failed to appropriate adequate funding. The circuit court rejected the claims, finding that the ballot initiative that enacted article IV, section 36(c) violated Mo. Const. art. III, 51, which prohibits initiatives from appropriating money without creating revenue to fund the initiative. The Supreme Court affirmed in part and vacated in part the circuit court's judgment, holding (1) article IV, section 36(c) does not appropriate money and does not remove the General Assembly's discretion in appropriating money to MO HealthNet; and (2) therefore, the circuit court erred in concluding that article IV, section 36(c) violates article III, section 51. View "Doyle v. Tidball" on Justia Law

The Supreme Court vacated the circuit court's judgment on the pleadings in favor of Governor Michael Parson and Michelle Hallford, the custodian of records for the governor's office (collectively, the Governor's Office) and dismissing the underlying lawsuit, holding that the Governor's Office was not entitled to judgment, as a matter of law, on the face of the pleadings. This lawsuit stemmed from two public records requests Plaintiff made under the Sunshine Law, Mo. Rev. Stat. 610.010-.035. Plaintiff argued that the Governor's Office violated the Sunshine Law when it required Plaintiff to prepay an estimate of costs for his first request, arbitrarily refused to waive fees associated with his first request, failed to explain its estimated delay in producing certain requested records, and impermissibly redacted certain records. The circuit court entered judgment on the pleadings in favor of the Governor's Office. The Supreme Court vacated the judgment, holding that the circuit court erred in sustaining the Governor's Office's motion for judgment on the pleadings as to several issues. View "Gross v. Parson" on Justia Law