Justia Missouri Supreme Court Opinion Summaries

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

The Supreme Court affirmed in part and vacated in part the grant of summary judgment in favor of the Marianist Provice of the United States and Chaminade College Preparatory, Inc. (together, Chaminade) and dismissing Plaintiff's claim that he suffered sexual abuse at the school in the early 1970s, holding that summary judgment for Chaminade on Plaintiff's claim of intentional failure to supervise was error.In granting summary judgment, the circuit court determined that Gibson v. Brewer, 952 S.W.2d 239 (Mo. band 1997), barred Plaintiff's negligence-based claims and that his intentional failure to supervise clergy claim was not supported by sufficient competent evidence. The Supreme Court vacated the summary judgment in part, holding (1) Gibson was properly decided, and the circuit court did not err in granting summary judgment as to the negligence counts as required by Gibson; and (2) given Chaminade's statement of material fact and the deposition testimony of Plaintiff's expert, summary judgment was improper on Plaintiff's claims of intentional failure to supervise. View "John Doe 122 v. Marianist Province of the United States" on Justia Law

The Supreme Court affirmed the decision and order of the Judicial Finance Commission (JFC) dismissing the Franklin County Commission's petition for review, holding that the JFC properly dismissed the petition as untimely.In this budgeting dispute, the Franklin County Commission filed a petition for review with the JFC. JFC ordered the petition to be dismissed, determining that the petition was untimely and that the JFC had not authority to grant the relief sought. The Supreme Court affirmed, holding (1) the Franklin County Commission failed to show good cause to excuse its late filing, and thus, the petition was properly dismissed as untimely; and (2) the Twentieth Judicial Circuit's motion for attorney fees is overruled without prejudice. View "Board of Commissioners of County of Franklin v. Twentieth Judicial Circuit" on Justia Law

The Supreme Court retransferred this case to the court of appeals for consideration of the merits of Appellants' claims after the court of appeals dismissed the appeals for lack of jurisdiction, holding that the circuit court's orders were eligible for certification as final under Rule 74.01(b).Appellants sued certain doctors and curators of the University of Missouri for injuries related with unsuccessful surgeries that Appellants underwent, alleging several torts, negligent misrepresentation, and violations of the Missouri Merchandising Practices Act. The circuit court entered orders dismissing the curators from each case and then certified those judgments as final under Rule 74.01(b). The court of appeals dismissed the appeals for lack of jurisdiction. The Supreme Court granted transfer and retransferred the case to the court of appeals for consideration of the merits of Appellants' claims, holding that the circuit court's orders were eligible for certification as final under Rule 74.01(b). View "Butala v. Curators of the University of Missouri" on Justia Law

The Supreme Court affirmed the judgment of the circuit court finding Defendant guilty of residing within 1,000 feet of George Washington Carver Middle School, holding that the circuit court did not err in concluding that Defendant was within 1,000 feet of the Carver Middle School property line.On appeal, Defendant argued that the circuit court erred in concluding that the word "school" as used in Mo. Rev. Stat. 566.147, includes the Carver Middle School building as well as the adjoining school property. The Supreme Court affirmed, holding that there was sufficient evidence supporting Defendant's conviction for residing within 1,000 feet of the Carver Middle School property line. View "State v. McCord" on Justia Law

The Supreme Court issued a permanent writ in prohibition directing Respondent, the Honorable Brian H. May, to vacate his orders in the case entered after Insurer filed its application for change of judge and to sustain the application for change of judge, holding that Insurer was entitled to the writ.In the underlying wrongful death suit Insurer filed a motion to intervene and stay proceedings while its contractual obligation to provide coverage was determined in a pending declaratory judgment action. Judge David Lee Vincent sustained the motion to intervene but overruled the motion to stay the proceedings. Thereafter, Judge Vincent entered an order of recusal, and the case was reassigned to Respondent. Insurer then filed this petition for writ of prohibition. The Supreme Court issued the writ and directed Respondent to vacate his order overruling Insurer's application for change of judge and the order sustaining a motion to quash Insurer's notice of deposition, holding that Insurer was entitled to a change of judge. View "State ex rel. COUNTRY Mutual Insurance Co. v. Honorable Brian H. May" on Justia Law