Justia Missouri Supreme Court Opinion Summaries

In 2020, C.S. pleaded guilty to two charges in the Lafayette County circuit court: possession of a controlled substance for possessing more than 35 grams of marijuana, and unlawful use of a weapon for possessing a firearm while knowingly in possession of a controlled substance. He was sentenced to seven years and four years of imprisonment, respectively, but the execution of his sentence was suspended. After his probation was revoked in 2021, C.S. was incarcerated. Following the approval of Amendment 3 in 2022, which allows expungement for certain marijuana offenses, C.S. filed a petition to expunge both convictions.The Lafayette County circuit court expunged C.S.'s conviction for possession of a controlled substance but denied the petition to expunge the conviction for unlawful use of a weapon. The court reasoned that the unlawful use of a weapon is a "weapons offense" and not eligible for expungement under the Missouri Constitution's article XIV, § 2.10(7)(a)c.The Supreme Court of Missouri reviewed the case and affirmed the circuit court's judgment. The court held that the offense of unlawful use of a weapon for possessing a firearm while knowingly in possession of a controlled substance is not a "marijuana offense" within the meaning of article XIV, § 2 of the Missouri Constitution. The court concluded that the primary purpose of the statute criminalizing unlawful use of a weapon is to prevent conduct that endangers others, and therefore, it is not eligible for expungement under the constitutional provision. View "C.S. v. Missouri State Highway Patrol Criminal Justice Information Service" on Justia Law

In August 2018, Jessie Nelson was seen at the scene of a shooting that resulted in one death and one permanent injury. He was charged with first-degree murder, first-degree assault, and two counts of armed criminal action. After a jury trial, Nelson was found guilty on all counts and sentenced in January 2020. The court of appeals affirmed the conviction in December 2021. Nelson filed a pro se Rule 29.15 motion in March 2022, and a public defender was appointed the same day. The public defender filed an amended motion in July 2022, which was overruled after an evidentiary hearing in August 2023. Nelson appealed.Cameron Woods was charged with unlawful use of a weapon and entered an open plea of guilt in March 2021. He was sentenced to 15 years’ imprisonment in May 2021. Woods did not appeal but filed a pro se motion under Rule 24.035 in October 2021. A public defender was appointed in November 2021, and an amended motion was filed in April 2022. The motion was overruled after an evidentiary hearing in November 2023. Woods appealed.The Supreme Court of Missouri reviewed the cases and found that both Nelson and Woods were abandoned by their appointed counsel due to untimely filing of amended motions. The court determined that remand for an abandonment inquiry was unnecessary as the records clearly showed abandonment. The court affirmed the motion courts' judgments, finding no clear error in their rulings on the merits after conducting evidentiary hearings. Nelson's claims of ineffective assistance of counsel were denied, and Woods' claim regarding the failure to call an expert witness at sentencing was also denied. The judgments denying postconviction relief were affirmed. View "Nelson v. State" on Justia Law

R.M.A., a transgender student who transitioned from female to male, attended public school in the Blue Springs R-IV School District. R.M.A. requested to use male-designated restrooms and locker rooms during the 2013-2014 and 2014-2015 school years, but the School District denied the request. R.M.A. filed a charge of discrimination with the Missouri Commission on Human Rights, alleging public accommodation discrimination based on sex. After receiving a notice of right to sue, R.M.A. filed a petition against the School District, claiming sex discrimination under the Missouri Human Rights Act (MHRA).The Circuit Court of Jackson County dismissed R.M.A.'s petition, stating that the public accommodation protection in section 213.065 does not cover claims based on gender identity. The Missouri Supreme Court reversed this decision in R.M.A. I, finding that R.M.A. had pleaded sufficient facts to establish a claim of sex discrimination and remanded the case for further proceedings. On remand, R.M.A. proceeded to trial, and the jury found the School District liable for sex discrimination, awarding R.M.A. compensatory and punitive damages.The School District filed a motion for judgment notwithstanding the verdict (JNOV) or, alternatively, a motion for a new trial, arguing that R.M.A. failed to make a submissible case for sex discrimination. The circuit court sustained the JNOV motion, finding that the evidence showed R.M.A. was excluded from male facilities due to female genitalia, not male sex. R.M.A. appealed.The Supreme Court of Missouri affirmed the circuit court's judgment, holding that R.M.A. did not present sufficient evidence that the School District's denial was based on R.M.A.'s male sex. The court concluded that the term "sex" in section 213.065 refers to biological sex, and the evidence indicated the School District's decision was based on R.M.A.'s female genitalia. Consequently, the court upheld the JNOV and denied R.M.A.'s motion for attorney fees. View "R.M.A. vs. Blue Springs R-IV School District" on Justia Law

Christopher Cole, an employee of The Kansas City Southern Railway Company (KCSR), sustained severe injuries while working, leading to the amputation of both legs. Cole filed a negligence claim under the Federal Employers’ Liability Act (FELA), asserting general negligence and negligence per se due to KCSR's violation of an Illinois close clearance regulation. The jury found KCSR liable and awarded Cole $12 million in damages, which the circuit court entered as judgment. The court later amended the judgment to include post-judgment interest.The Circuit Court of St. Louis County presided over the initial trial. The jury found Cole 21 percent at fault and KCSR 79 percent at fault. KCSR filed motions for a new trial and for judgment notwithstanding the verdict (JNOV), both of which were overruled. Cole subsequently filed a motion to amend the judgment to include post-judgment interest, which the circuit court granted.The Supreme Court of Missouri reviewed the case. The court affirmed the circuit court’s judgment in many respects but vacated the $12 million damages award and the post-judgment interest. The court held that the circuit court erred in submitting jury instructions that deprived KCSR of its contributory negligence defense under FELA. The court also found that the circuit court lacked jurisdiction to amend its judgment to include post-judgment interest after the original judgment became final. The Supreme Court of Missouri remanded the case to the circuit court to reduce the damages award to $9.48 million, reflecting Cole’s contributory negligence, and to enter judgment without post-judgment interest. View "Cole v. The Kansas City Southern Railway Co." on Justia Law

Diana Penney, a pharmacy technician from 1980 to 2019, filed multiple work-related occupational disease claims due to repetitive activities at her job. She was diagnosed with low back issues, protruding disks in her neck and upper back, and carpal tunnel syndrome. Penney underwent surgeries and stopped working in August 2019 due to pain from these conditions. She sought permanent total disability (PTD) benefits from the Second Injury Fund (the Fund).An administrative law judge (ALJ) concluded that Penney was permanently and totally disabled due to the combined effect of her occupational diseases and awarded her PTD benefits from the Fund. The Fund appealed to the Labor and Industrial Relations Commission, arguing that the ALJ improperly considered Penney’s preexisting occupational diseases under the relevant statutory category. The Commission disagreed and affirmed the ALJ’s award.The Supreme Court of Missouri reviewed the case and held that preexisting occupational diseases do not qualify as preexisting disabilities under section 287.220.3(2)(a)a(ii)1, which requires the disability to be a “direct result of a compensable injury as defined in section 287.020.” The court noted that section 287.020 encompasses injuries by accident and explicitly excludes occupational diseases. The court emphasized that the legislature’s choice to reference only section 287.020 in the statute indicates an intent to limit qualifying preexisting disabilities to accidental injuries. Consequently, the court reversed the Commission’s decision, ruling that Penney’s preexisting occupational diseases could not be considered in determining her entitlement to PTD benefits from the Fund. View "Treasurer v. Penney" on Justia Law

James Eckardt, an aircraft mechanic, sustained multiple work-related injuries over his 40-year career, including injuries to his knees, shoulders, wrists, and cervical spine. His final injury occurred in October 2015, leading to a spinal fusion surgery. Eckardt retired in February 2017 due to his inability to perform his job duties and sought permanent total disability (PTD) benefits from the Treasurer of Missouri as Custodian of the Second Injury Fund.An administrative law judge (ALJ) in the Division of Workers’ Compensation assigned permanent partial disability (PPD) amounts to Eckardt’s preexisting injuries and determined he was permanently and totally disabled, awarding PTD benefits. The Fund appealed to the Labor and Industrial Relations Commission, arguing that the ALJ improperly considered non-qualifying injuries, including carpal tunnel syndrome and a right shoulder injury, in the PTD determination. The Commission reversed the ALJ’s decision, finding that the doctor’s reliance on the non-qualifying right shoulder injury meant there was no credible evidence that Eckardt was permanently and totally disabled due to the primary injury in combination with only qualifying preexisting injuries.The Supreme Court of Missouri reviewed the case and affirmed the Commission’s denial of PTD benefits. The Court held that Eckardt’s right shoulder injury did not qualify as a preexisting disability because it did not meet the statutory threshold of 50 weeks PPD, and a load factor could not be applied to enhance the PPD amount. The Court also found that Eckardt failed to show he was permanently and totally disabled due to the combination of his primary injury and only his qualifying preexisting disabilities, as the doctor’s opinion improperly included the non-qualifying right shoulder injury. Therefore, Eckardt did not meet his burden of proof for Fund liability, and his claim for PTD benefits was denied. View "Eckardt v. Treasurer" on Justia Law

Trent Berhow, while incarcerated at Western Missouri Correctional Center, fell from a ladder and subsequently filed a lawsuit against the state of Missouri, alleging that his supervisor's instructions created a dangerous condition leading to his injury. Berhow filed his suit more than a year after the incident, which brought into question the statute of limitations.Initially, Berhow sued the Missouri Department of Corrections. The department moved to dismiss the petition, citing the statute of limitations. Berhow then amended his petition to dismiss the department and add the state as the defendant. The Circuit Court of DeKalb County overruled the state's first motion for judgment on the pleadings but later sustained the state's renewed motion, which argued both sovereign immunity and the statute of limitations. Berhow's motion for sanctions was also effectively overruled by the circuit court.The Supreme Court of Missouri reviewed the case de novo. The court held that Berhow's claim was barred by the statute of limitations under section 516.145, which requires actions against the Department of Corrections or any entity thereof to be brought within one year. The court reasoned that allowing Berhow to sue the state instead of the department would defeat the purpose of the statute, as the department acts on the state's behalf. The court affirmed the circuit court's judgment, concluding that the statute of limitations barred Berhow's claim. View "Berhow v. State" on Justia Law

Robert J. Branson was charged with six sex crimes, including three unclassified felonies, for raping and sodomizing a child. On the day of the trial, Branson negotiated an Alford plea to one count of first-degree child molestation (class A felony) and two counts of second-degree statutory rape. The State amended the charges accordingly. During the plea hearing, Branson acknowledged he was charged with a class A felony and faced a potential life sentence. The circuit court accepted his plea and sentenced him to life imprisonment for the class A felony and consecutive seven-year terms for the two counts of second-degree statutory rape.Branson filed a Rule 24.035 motion for postconviction relief but did not allege a factual defect in his guilty plea or that his sentence exceeded the statutory maximum. The circuit court overruled the motion. On appeal, Branson claimed for the first time that the State failed to allege the necessary facts for a class A felony. The court of appeals affirmed the judgment, holding that Branson waived this argument by not raising it in his Rule 24.035 motion.Branson then filed a petition for a writ of habeas corpus, alleging his sentence was excessive because the factual basis for his guilty plea only supported a class B felony. The circuit court denied the petition, but the court of appeals granted it. The Supreme Court of Missouri reviewed the case and denied habeas relief, holding that Branson waived his sentencing claim by not raising it in his Rule 24.035 motion. The court found no jurisdictional defect, cause and prejudice, or manifest injustice warranting habeas review of the procedurally defaulted claim. The court overruled previous cases that allowed habeas review for sentencing errors as jurisdictional defects. View "Branson v. Shewmaker" on Justia Law

Registered Missouri voters Raymond McCarty, Daniel Shaul, Russell Lahl, and Michael Hastings, along with several nonprofit organizations, contested the results of the November 2024 election approving Proposition A. They argued that the summary statement and fiscal note summary for Proposition A were misleading, casting doubt on the election's fairness and validity. Proposition A proposed increasing the minimum wage, adjusting it based on the Consumer Price Index, requiring paid sick leave, and exempting certain entities.The Missouri Supreme Court reviewed the case. The lower courts had not previously reviewed this specific election contest. The plaintiffs brought the case directly to the Missouri Supreme Court, which has original jurisdiction over election contests under chapter 115 of the Missouri statutes.The Missouri Supreme Court held that the summary statement and fiscal note summary for Proposition A were not misleading or materially inaccurate. The court found that the summary statement fairly and impartially summarized the central features of Proposition A, and the fiscal note summary adhered to statutory requirements by focusing on governmental costs. The court concluded that there was no election irregularity of sufficient magnitude to cast doubt on the election's validity. Additionally, the court dismissed the plaintiffs' claims that Proposition A violated the "single subject" and "clear title" requirements of the Missouri Constitution, citing a lack of original jurisdiction over these claims. The court upheld the election results, affirming the validity of Proposition A. View "McCarty v. Secretary of State" on Justia Law

In 2015, the Missouri General Assembly enacted sections 67.287 and 479.359.2, which imposed certain standards and revenue caps on municipalities, specifically targeting St. Louis County. The City of Normandy and other municipalities challenged these statutes, claiming they violated the Missouri Constitution's prohibition against local or special laws. In 2016, the Circuit Court of Cole County declared these sections unconstitutional and issued a permanent injunction against their enforcement. The Missouri Supreme Court affirmed this decision in City of Normandy v. Greitens.Following a shift in legal analysis in City of Aurora v. Spectra Communications Group, LLC, the state sought relief from the 2016 injunction, arguing that the statutes would have survived under the new rational basis review. The circuit court initially granted this relief, but the Missouri Supreme Court vacated that judgment in City of Normandy v. Parson, remanding the case for further proceedings. On remand, the circuit court overruled the state's motion for partial relief from the judgment.The Missouri Supreme Court reviewed the case and affirmed the circuit court's decision. The court held that the change in legal analysis from City of Aurora did not automatically warrant relief from the permanent injunction under Rule 74.06(b)(5). The court emphasized the importance of finality in judgments and found that the state did not demonstrate sufficient inequity to justify lifting the injunction. The court also noted that the state had not sought relief from the declaratory judgment that the statutes were unconstitutional, which remained in effect. Therefore, the circuit court did not abuse its discretion in denying the state's motion for relief. View "City of Normandy v. Kehoe" on Justia Law