Justia Missouri Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the motion court overruling Appellant's Rule 24.035 amended motion seeking to set aside his guilty plea and vacate his judgment and sentence, holding that the motion court's findings of fact and conclusions of law were not clearly erroneous.Appellant pleaded guilty to first-degree involuntary manslaughter and armed criminal action and was sentenced to two consecutive terms of fifteen and twenty-five years' imprisonment. Appellant later filed a pro se Rule 24.035 to vacate, set aside, or correct the judgment and sentence. The motion court granted the motion, set aside Appellant's guilty plea, and reinstated his original charges. Thereafter, Appellant pled guilty to second-degree murder and armed criminal action and was sentenced to concurrent terms of life and thirty years' imprisonment. Appellant then filed a second Rule 24.035 motion. The motion court overruled the motion. The Supreme Court affirmed, holding that the motion court did not err. View "Staten v. State" on Justia Law

The Supreme Court reversed the judgment of the postconviction relief court overruling Appellant's Rule 24.035 motion for postconviction relief, holding that the mistaken belief held by Defendant regarding his sentencing, which arose from his plea counsel's direct assurance, resulted in his plea of guilty.After Defendant pleaded guilty to driving while intoxicated plea counsel advised him he would be eligible for long-term treatment under Mo. Rev. Stat. 217.362. The circuit court sentenced Defendant pursuant to that provision, but after sentencing, Defendant discovered he was statutorily ineligible for placement in the program. Defendant filed a motion to vacate, set aside or correct his judgment or sentence, arguing that his guilty plea was involuntary unknowing, and unintelligent. The postconviction relief court overruled the motion. The Supreme Court reversed, holding that prejudice existed and, therefore, the judgment overruling Defendant's motion was clearly erroneous. View "Hefley v. State" on Justia Law

The Supreme Court vacated the judgment of the circuit court in favor of Michael Holmes on his claim that the state legal expense fund (SLEF) was obligated to pay his 2016 judgment against two former officers of the St. Louis Metropolitan Police Department, holding that Holmes failed to show that he was entitled to a declaration that the State was obligated to pay his judgment out of SLEF.On appeal, the State argued that the circuit court erroneously applied the version of Mo. Rev. Stat. 105.726.3 in effect when the former police officers filed a false report that caused Holmes's wrongful arrest and conviction rather than the version in effect when Holmes filed his claim in a suit against the former officers. The Supreme Court vacated the judgment below, holding (1) a right to payment from SLEF does not arise until a claim is made, and therefore, section 105.726.3 governed Holmes's claim; and (2) SLEF was prohibited from paying any claim or judgment against the police officers. View "Holmes v. Steelman" on Justia Law