Justia Missouri Supreme Court Opinion Summaries

The Supreme Court made permanent a preliminary writ of prohibition it issued ordering the circuit court to take no other action in this wrongful death action other than to dismiss Sergeant Dirk Helms and Chief Joe Edwards of the De Soto Police Department, holding that the doctrine of official immunity prohibited Missouri courts from holding Helms and Edwards personally liable for any negligence.Plaintiff's daughter was a passenger in a vehicle who died during an automobile accident in the course of a police pursuant by Officer David Karssinger. Helms and Edwards filed separate motions to dismiss the claims against them, alleging that the claims were barred by official immunity and the public duty doctrine. After the circuit court overruled the motions Helms and Edwards sought this writ of prohibition. The Supreme Court granted the requested relief, holding that Helms and Edwards may have been negligent in failing to fulfill discretionary duties with due regard for the public safety and in such a way as to protect Plaintiff's daughter, but they were protected from liability by the doctrine of official immunity. View "State ex rel. Helms v. Honorable Joseph Alfred Rathert" on Justia Law

The Supreme Court affirmed the judgment of the circuit court declining to award Arrowhead Lake Estates Homeowners Association, Inc. attorney's fees after awarding Arrowhead Lake injunctive relief, holding that the circuit court did not abuse its discretion.Arrowhead Lake filed a petition for injunctive relief seeking to have an unapproved building removed and to be awarded attorney's fees. The circuit court ordered Homeowner to remove the unapproved building but did not award Arrowhead Lake attorney's fees. Arrowhead Lake appealed, arguing that it was entitled to attorney's fees based upon the language of the "Declaration of Covenants, Easements, and Restrictions of Arrowhead Lake Estates Subdivision." The Supreme Court affirmed, holding that where the Declaration's clear intent to provide recovery to a prevailing "lot owner" who brings suit to enforce the Declaration's terms and where Arrowhead Lake never claimed it was a "lot owner," the circuit court properly declined to award attorney's fees. View "Arrowhead Lake Estates Homeowners Ass'n, Inc. v. Aggarwal" on Justia Law

The Supreme Court affirmed in part and vacated in part the judgment of the circuit court awarding a class of Missouri corrections officers $113 million plus post-judgment interest for breach of contract, holding that the circuit court's determination that all preshift and postshift activities are compensable was erroneous.On appeal, the Missouri Department of Corrections (MDOC) argued that the circuit court erroneously determined that MDOC was liable on the corrections officers' breach of contract claims for time spent performing all preshift and postshift activities. The Supreme Court held (1) the circuit court erred in determining that all corrections officers' preshift and postshift activities were compensable principal activities that must be compensated; (2) because the award of damages and the court's declaratory and injunctive relief were based on the erroneous finding of liability, those rulings were erroneous; and (3) the circuit court correctly determined that MDOC must compensate corrections officers for time spent retrieving keys and radios and time spent monitoring and supervising offenders while not on post. View "Hootselle v. Missouri Department of Corrections" on Justia Law

The Supreme Court affirmed the judgment of the circuit court overruling Defendant's Rule 29.15 motion for postconviction relief, holding that the circuit court's findings of fact and conclusions of law were not clearly erroneous.Defendant was convicted of two counts of first-degree murder, five counts of armed criminal action, and one count each of first-degree burglary, forcible rape, and forcible sodomy. Defendant was sentenced to death for each murder count. In his postconviction motion, Defendant argue that the State committed multiple Brady violations and that trial counsel provided ineffective assistance. The Supreme Court affirmed, holding that the circuit court's findings of fact and conclusions of law were not clearly erroneous. View "Driskill v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court finding the challenged provisions of House Bill No. 1413 violated multiple provisions of the Missouri Constitution and permanently enjoining its operation and enforcement, holding that HB 1413 is void in its entirety.HB 1413, which was enacted in 2018, significantly altered many aspects of public labor relations in the state. The circuit court found (1) the exemption of public safety labor organizations in Mo. Rev. Stat. 105.503.2(1) violates public employees' right to bargain collectively through representatives of their own choosing, in violation of article I, section 29; and (2) the exemption of public safety labor organizations violated Mo. Const. art. I, 29. The Supreme Court affirmed, holding (1) the circuit court did not err in finding that the exemption of public safety labor organizations violates multiple provisions of the Missouri Constitution and in permanently enjoining Defendants from administering or enforcing any provision of HB 1413; and (2) the operation of the subject exemption forces the Court to declare HB 1413 void in its entirety rather than sever the offending provision. View "Missouri National Education Ass'n v. Missouri Department of Labor & Industrial Relations" on Justia Law

The Supreme Court vacated and remanded the judgment of the circuit court dismissing Appellants' lawsuit against the Missouri Sheriffs' Retirement System (MSRS), holding that the statute authorizing a $3 surcharge violates Mo. Const. art. I, 14.At issue was Mo. Rev. Stat. 57.955, which provides that a $3 surcharge shall be assessed and collected in all state civil actions and in all criminal cases including violation of criminal or traffic laws, including infractions. Appellants received speeding tickets and pled guilty and paid court costs. Unbeknownst to Appellants was that three dollars of the total costs was the surcharge authorized by section 57.955. Appellants, on behalf of a putative class, sued MSRS, alleging that the purchase violated article I, section 14 of the Missouri Constitution. The circuit court dismissed the case, concluding (1) Appellants failed to join the clerks responsible for assessing, collecting, and remitting the surcharge as necessary and indispensable parties; and (2) the statute was not unconstitutional. The Supreme Court reversed, holding (1) the municipal court clerks were not necessary and indispensable parties; and (2) section 57.955 is not "reasonably related to the expense of the administration of justice" and therefore violates article I, section 14 of the Missouri Constitution. View "Fowler v. Missouri Sheriffs' Retirement System" on Justia Law

The Supreme Court affirmed the decision of the circuit court granting judgment on the pleadings in favor of the Affton Fire Protection District, the governor, and the attorney general (collectively, Defendants) in this challenge to Mo. Rev. Stat. 72.418.2 and 321.322.3, holding that the circuit court did not err.The City of Crestwood and two of its resident taxpayers (collectively, Plaintiffs) argued that sections 72.418.2 and 321.322.3, which govern the provision of and payment for fire protection services in certain annexed areas, violate the prohibition against special laws in Mo. Const. art. III, 40 and that section 72.418.2 violates constitutional due process protections and provisions of the Missouri Constitution prohibiting certain taxes and the creation of unfunded mandates. The Supreme Court held (1) a rational basis supported the classification scheme in sections 72.418 and 321.322.3; (2) the fee Crestood pays to the district is not a tax on the resident taxpayers of Crestwood; and (3) section 72.418.2 does not create an unfunded mandate. View "City of Crestwood v. Affton Fire Protection District" on Justia Law

The Supreme Court affirmed the circuit court's judgment in favor of the Empire District Electric Company and Westar Generating, Inc. (collectively, the Utilities) in this petition to quiet title against John Scorse, both individually and as a trustee, and his successors in interest concerning a tract of land in Newton County, holding that the circuit court did not err.After the circuit court entered its judgment, Scorse filed a motion to amend the judgment, arguing that the circuit court misapplied the law by failing to grant his adverse possession claim. The circuit court overruled the motion. The Supreme Court affirmed, holding that the facts, combined with the facts found by the circuit court in its final judgment after trial, were not such that Scorse was entitled to judgment as a matter of law on his claim of adverse possession. View "Empire District Electric Co. v. Scorse" on Justia Law

The Supreme Court vacated the Labor and Industrial Relations Commission awarding permanent total disability (PTD) benefits to Jonathan Parker under Mo. Rev. Stat. 287.220.2, holding that the Labor and Industrial Relations Commission erred in applying subsection 2 of section 287.220 rather than subsection 3 of the statute, and remand was required.Before the Supreme Court, the Second Injury Fund argued that Parker should be denied benefits under subsection 3. Parker, in turn, argued that the Supreme Court should award him benefits under subsection 3. The Supreme Court vacated the Commission's decision, holding (1) under Mo. Const. art. V, 18, the Supreme Court is permitted to review only the decisions and findings of the Commission, not to make such decisions in the first place; and (2) therefore, remand to the Commission was required to determine whether Parker was entitled to benefits under subsection 3. View "Treasurer of State as Custodian of the Second Injury Fund v. Parker" on Justia Law

The Supreme Court made permanent a preliminary writ of prohibition directing the circuit court to enter summary judgment in favor of Brian Henderson and Beutler, Inc., d/b/a George J. Shaw Construction Co. (Shaw), for injuries Joshua McArthur sustained while operating a dump truck on a construction site, holding that both Henderson and Shaw were immune from suit.In their motion for summary judgment, Henderson and Shaw asserted immunity from suit under the workers' compensation exclusivity doctrine. The circuit court overruled the motion, finding that the exception from workers' compensation exclusivity found in Mo. Rev. Stat. 287.040.4 applied. The Supreme Court affirmed, holding that the circuit court's findings regarding the application of section 287.040.4 were erroneous. View "State ex rel. Beutler, Inc. v. Honorable Sandra C. Midkiff" on Justia Law