Justia Missouri Supreme Court Opinion Summaries

Kevin Rhodes, a former employee of the Missouri Highways and Transportation Commission, was terminated in December 2019 following an investigation into allegations of workplace misconduct, including the use of a racial slur. Rhodes filed grievances about his treatment during the investigation and, after his termination, brought charges of discrimination with the Missouri Commission on Human Rights. He subsequently received notices of right to sue and filed a lawsuit in circuit court alleging sex discrimination, retaliation, and hostile work environment under the Missouri Human Rights Act.A jury in the Circuit Court of Jackson County found in favor of the commission on the sex discrimination claim but ruled for Rhodes on his retaliation and hostile work environment claims, awarding him various damages. The circuit court applied a statutory damages cap and entered judgment accordingly. The commission moved for judgment notwithstanding the verdict, which the circuit court denied. Both parties appealed: Rhodes challenged the constitutionality of the damages cap, while the commission argued that Rhodes had not made a submissible case. The case was transferred to the Supreme Court of Missouri due to the constitutional issues raised.The Supreme Court of Missouri determined that the circuit court’s judgment was not final because it failed to address Rhodes’s requests for equitable relief and prejudgment interest. The court explained that a final judgment must dispose of all claims and forms of relief sought. Because the judgment did not resolve all aspects of Rhodes’s claims, the Supreme Court of Missouri dismissed the appeal for lack of a final judgment, declining to address the merits of the parties’ arguments. View "Rhodes v. Missouri Highways and Transportation Commission" on Justia Law

David Carter, who was 61 years old when he began working for the Missouri Department of Corrections, experienced repeated harassment from his supervisor, including disparaging remarks about his age and his medical condition, shingles. The supervisor’s conduct included denying Carter access to necessary tools and training, which worsened Carter’s health issues and ultimately led to his resignation. Carter subsequently filed a lawsuit alleging violations of the Missouri Human Rights Act, claiming constructive discharge due to age and disability discrimination, hostile work environment, and retaliation. In his petition, Carter sought compensatory and punitive damages, attorney fees, costs, prejudgment and post-judgment interest, and equitable relief.A jury in the Circuit Court of Jackson County found in Carter’s favor, awarding him substantial damages for non-economic harm, back pay, future economic losses, and punitive damages. The circuit court initially entered judgment for the full amount of the jury’s award, then later amended the judgment to reduce the damages in accordance with the statutory cap under section 213.111.4. The court also awarded attorney fees and costs but did not address Carter’s requests for prejudgment interest or equitable relief in its final judgment.The Supreme Court of Missouri reviewed the case on appeal. The court determined that the circuit court’s judgment was not final because it failed to resolve Carter’s requests for prejudgment interest and equitable relief, and did not include a statement denying all other requested relief. As a result, the Supreme Court of Missouri dismissed the appeal for lack of a final judgment, without reaching the merits of the parties’ arguments regarding the damages cap, attorney fees, or the sufficiency of the evidence. View "Carter v. Missouri Department of Corrections" on Justia Law

After Missouri voters approved a constitutional amendment in November 2024 protecting the right to make decisions about reproductive healthcare, Planned Parenthood filed a lawsuit in the Circuit Court of Jackson County. The organization sought a declaration that various state abortion laws and regulations were unconstitutional under the new amendment and requested a preliminary injunction to prevent their enforcement while the case was pending. The circuit court initially granted a preliminary injunction enjoining several abortion-related statutes and regulations, and later expanded the injunction to include additional licensing requirements after a motion for reconsideration.The State of Missouri challenged the preliminary injunction, arguing that the circuit court applied the wrong legal standard. The Supreme Court of Missouri issued a peremptory writ directing the circuit court to vacate its orders and reconsider the injunction under a more rigorous standard, requiring a threshold finding that the party seeking the injunction is likely to prevail on the merits. The circuit court complied, reevaluated the request, and again issued a preliminary injunction enjoining the same statutes and regulations. The State then appealed directly to the Supreme Court of Missouri, raising multiple points of error and seeking a stay and expedited review.The Supreme Court of Missouri determined that it lacked exclusive appellate jurisdiction over the appeal because the circuit court had not yet ruled on the constitutional validity of the challenged statutes. The Court explained that its exclusive jurisdiction is only invoked when a claim that a statute is unconstitutional has been properly raised, preserved, and ruled upon in the lower court. Since the appeal concerned only the issuance of a preliminary injunction and not a final determination on the statutes’ validity, the Supreme Court of Missouri transferred the case to the Missouri Court of Appeals, Western District, for further proceedings. View "Comprehensive Health of Planned Parenthood Great Plains v. State" on Justia Law

Robust Missouri Dispensary 3, LLC, operates a dispensary in Florissant, an incorporated city in St. Louis County. After Missouri voters approved a constitutional amendment legalizing non-medical marijuana and allowing local governments to impose a 3 percent sales tax, both Florissant and St. Louis County enacted such a tax. Robust collected and remitted the tax to Florissant but not to St. Louis County. The Missouri Department of Revenue notified Robust that it must also remit the tax to St. Louis County. Robust sought declaratory and injunctive relief, arguing that the constitutional amendment only allows a village, town, or city in an incorporated area to impose the tax, not a county.The Circuit Court of St. Louis County granted summary judgment in favor of St. Louis and St. Charles Counties, finding that the definition of "local government" includes a county in an incorporated area. The court reasoned that excluding counties from the definition would frustrate the amendment's purpose of protecting public health. Robust appealed the decision.The Supreme Court of Missouri reviewed the case de novo and found that the plain language of the constitutional amendment distinguishes between incorporated and unincorporated areas. The court held that in an incorporated area, only a village, town, or city can impose the 3 percent sales tax, while in an unincorporated area, only a county can impose the tax. The court vacated the circuit court's judgment and remanded the case to enter judgment in favor of Robust, ruling that St. Louis County cannot impose the tax on sales within Florissant. View "Robust Missouri Dispensary 3, LLC v. St. Louis County" on Justia Law

Christopher Scott was charged with first-degree robbery, armed criminal action, and unlawful use of a weapon. After a jury trial, he was found guilty on all counts and sentenced in November 2020. The Missouri Court of Appeals affirmed his conviction, and the mandate was issued on January 19, 2022. Scott then filed a pro se Rule 29.15 motion for postconviction relief on April 11, 2022, raising three claims. A public defender entered an appearance on his behalf but did not request an extension to file an amended motion. The public defender filed an amended motion on August 4, 2022, raising six claims, including the original three. The motion court denied relief on all claims after an evidentiary hearing.The Missouri Court of Appeals reviewed the case and transferred it to the Supreme Court of Missouri. The Supreme Court of Missouri noted that the amended motion was filed late and without an extension request. The court emphasized that the deadlines in Rule 29.15 are mandatory and that the abandonment doctrine, which can excuse untimely filings, applies only to appointed counsel, not to unappointed counsel. Since the public defender was not officially appointed, the abandonment doctrine did not apply.The Supreme Court of Missouri held that the motion court should not have considered the untimely claims in the amended motion. As Scott did not challenge the denial of his original pro se claims, the court affirmed the motion court's judgment denying postconviction relief on those claims. The court concluded that the amended motion's additional claims were not properly before the motion court due to the untimely filing. Therefore, the judgment of the motion court was affirmed. View "Scott v. State" on Justia Law

Cedric Mack was charged with driving while intoxicated as a persistent offender. After a jury trial, he was found guilty and sentenced by the circuit court. Mack appealed, and the court of appeals affirmed his conviction. Subsequently, Mack filed a pro se Rule 29.15 motion for postconviction relief, which included a request for a public defender. A public defender later entered an appearance and filed an amended motion. The motion court overruled the amended motion after an evidentiary hearing. Mack appealed, and the court of appeals remanded the case for findings of fact, conclusions of law, and an abandonment inquiry. On remand, the motion court found the public defender had abandoned Mack, considered the amended motion on the merits, and denied relief again. Mack appealed.The Supreme Court of Missouri reviewed the case. The court noted that Mack's amended motion was not timely filed under the applicable version of Rule 29.15(g). The court also found that the public defender's entry of appearance without being appointed meant the abandonment doctrine did not apply. Consequently, the only issue was whether Mack's single pro se claim needed to be resolved again. The court determined it did not, as the claim had already been raised and decided in Mack's direct appeal.The Supreme Court of Missouri held that Mack's pro se Rule 29.15 motion was the only timely filed motion and contained a single claim identical to one previously rejected on direct appeal. Therefore, the judgment of the motion court denying postconviction relief was affirmed. View "Mack v. State" on Justia Law

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