Justia Missouri Supreme Court Opinion Summaries

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

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