Justia Missouri Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court determining that Mo. Rev. Stat. 595.201, as applied to defense attorneys, is constitutionally invalid and that the passage of Senate Bill 569 (SB 569) was procedurally proper, holding that the circuit court did not err in its judgment.Plaintiffs - five public defenders and three criminal defendants - brought this action for declaratory and injunctive relief challenging the constitutional validity of statutes relating to victims of sexual offenses, including SB 569 and section 595.021, which requires criminal defense attorneys to provide information to victims of sexual assault offenses. The circuit court (1) declared section 595.201 constitutionally invalid as as applied to defense counsel because it violated defense attorneys' rights to freedom of speech, and (2) rejected procedural challenges to SB 569 as a whole. The Supreme Court affirmed, holding that the circuit court properly determined that (1) section 595.201.2(4)'s requirements violate defense attorneys' free speech rights, and (2) the General Assembly complied with the procedural limitations imposed by the Missouri Constitution in passing SB 569. View "Fox v. State" on Justia Law

The Supreme Court reversed the decision of the circuit court sustaining Defendant's motion to dismiss one count of possession of a controlled substance, holding that the circuit court's decision to dismiss the possession count on double jeopardy grounds was erroneous.Defendant was charged with five counts, including the possession count and one count of unlawful use of a weapon by possessing a firearm while in possession of a controlled substance (UUW-possession), all stemming from the same incident. Defendant plead guilty to all counts except the possession count, arguing that because he had been convicted of the greater offense of UUW-possession via his guilty plea, any subsequent prosecution for possession would constitute a double jeopardy violation. The circuit court dismissed the possession count. The Supreme Court reversed, holding that the circuit court erred by dismissing the possession count against Defendant. View "State v. Andrews" on Justia Law

The Supreme Court dismissed this appeal from the decision of the Labor and Industrial Relations Commission (Commission) reversing the administrative law judge's award and denying Claimant permanent total disability benefits, holding that Claimant's brief preserved nothing for appellate review because it failed to comply with the mandatory and straightforward rules governing the contents of an appellant's briefs.After the Commission denied Claimant's claim, Claimant appealed. The Supreme Court dismissed the appeal, holding that each of Claimant's points on appeal was defective because each point relied on wholly failed to follow the simple template provided in Rule 84.04. View "Lexow v. Boeing Co." on Justia Law

The Supreme Court granted a preliminary writ of prohibition to Kimberly Barks preventing the disclosure of her medical records, holding that Barks did not waive the physician-patient privilege by pleading the affirmative defenses of comparative fault and assumption of risk.A golf cart driven by Barks and ridden in by Sheila Spencer was involved in an accident. Spencer sued Barks, alleging negligence. Barks denied the allegations and, alternatively, asserted several affirmative defenses, including comparative fault and implied primary assumption of risk. Spencer sought discover of Barks' medical records from the night of the accident, which Barks objected to. The circuit court subsequently sustained Spencer's motion to compel discovery of Barks' medical records. Barks then filed a petition for writ of prohibition or mandamus. The Supreme Court granted the writ, holding that Barks's affirmative defense did not constitute a waiver of the physician-patient privilege. View "State ex rel. Barks v. Honorable Pelikan" on Justia Law

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