Justia Missouri Supreme Court Opinion Summaries

by
On August 12, 2018, Rachel Sender suffered injuries in a bicycle accident on a bike path in Forest Park, St. Louis. Sender claimed her injuries were due to a defect on the path, and she notified the City of St. Louis of her injury, as per section 82.210. This statute states that a claimant should provide the mayor of the city with notice within 90 days of an injury occurring due to a defect in any city property listed in the statute. The City of St. Louis responded that Sender's notice was inadequate as it did not sufficiently identify the location of the incident. After the 90-day statutory period, Sender provided further information to the City. The City moved to dismiss Sender's claims based on the insufficiency of the notice, which was allowed by the circuit court.Sender appealed this decision to the Supreme Court of Missouri. The court first had to decide whether the bike path is considered a "thoroughfare" as per section 82.210. It concluded that the bike path was a thoroughfare because it was a publicly maintained exterior improvement facilitating pedestrian traffic. As such, Sender was required to provide notice of her claim to the City.The court then had to determine whether Sender's notice was sufficient. However, Sender did not provide any record of the evidentiary hearing held by the circuit court to determine the sufficiency of the notice. The Supreme Court thus affirmed the circuit court's decision to dismiss Sender's claims, as it could not review the sufficiency of the notice without the transcript of the hearing. View "Sender v. City of St. Louis" on Justia Law

by
The Supreme Court of Missouri affirmed the judgment of the Circuit Court of Jefferson County terminating a father's parental rights to his child. The father had been convicted of two felony violations, each involving a child victim. The father appealed the decision, arguing that his felony violations were not statutory grounds justifying the termination of his parental rights, that these grounds should be declared unconstitutional, and that there was insufficient evidence to declare him an unfit parent. However, the Supreme Court found that the father's first two arguments were not preserved for appeal and therefore declined to address them. The court ruled that there was sufficient evidence to terminate the father's parental rights, upholding the lower court's decision. The court found the termination was in the best interest of the child. View "In the Interest of: E.G. v. Juvenile Officer" on Justia Law

Posted in: Family Law
by
The Supreme Court of Missouri reversed a lower court's judgment in a negligence case involving a hospital and an individual who was shot on the hospital's property. The plaintiff, Steven Harner, had sued Mercy Hospital Joplin, alleging the hospital had breached its duty to protect him from the criminal acts of a third person on its property. The case revolved around the "known third person exception" to the general rule that businesses have no duty to protect invitees from the criminal acts of third parties. According to this exception, a duty may arise when a person known to be violent is present on the premises, or an individual is present who has conducted himself so as to indicate danger, and sufficient time exists to prevent injury. The court found that the defendant, Mercy Hospital, could not have reasonably foreseen that the third person in question, who had committed a non-violent theft on the premises prior to the shooting, would suddenly become violent. As such, the court held that Mercy Hospital did not owe a duty of care to Harner under the known third person exception and reversed the lower court's judgment. The case was remanded for further proceedings. View "Harner vs. Mercy Hospital Joplin" on Justia Law

by
The Supreme Court of Missouri dismissed an appeal from the City of Harrisonville and Brad Ratliff (collectively, "the City"), who were challenging a ruling by the lower court in favor of the Missouri Department of Natural Resources ("MDNR") and the Board of Trustees for the Petroleum Storage Tank Insurance Fund ("the Fund Board"). The case was initially about the City's requests for certain documents related to the conduct of the executive director of the Fund, which the MDNR and the Fund Board had refused to disclose, citing several Missouri statutes. The City alleged that the MDNR had knowingly violated Missouri's Sunshine Law. The circuit court granted summary judgment to the MDNR and the Fund Board, and the court of appeals affirmed that judgment. The City then appealed to the Supreme Court of Missouri. However, the Supreme Court dismissed the appeal due to the City's failure to properly brief any allegations of reversible error, as required by Rule 84.13(a), and the City's failure to comply with the basic requirements of Rule 84.04(d). The court noted that the City's points of contention did not follow the required format and failed to identify any claim of reversible error in the circuit court's judgment. The court also pointed out that there is no right to appeal from a court of appeals decision, and such a claim is categorically unreviewable. Even if the court had decided to review the City's appeal, the circuit court's judgment would have been affirmed because the City only purported to appeal the summary judgment based on one subsection of § 610.021, while summary judgment was granted on two subsections of that statute. View "City of Harrisonville v. Missouri Dept. of Natural Resources" on Justia Law

by
The Supreme Court of Missouri reversed the circuit court's ruling and held that the Truly Agreed and Finally Passed House Bill 1606 (2022) (“TAFP HB 1606”) violated the single subject requirement of article III, section 23 of the Missouri Constitution. The bill was initially proposed to reduce the amount of information certain counties had to publish in their financial statements. However, the bill underwent several modifications, including the addition of section 67.2300, which imposed restrictions on the expenditure of state funds for combating homelessness and made unauthorized sleeping and camping on state-owned lands a class C misdemeanor. The appellants, including a group of individuals and a non-profit organization, argued that the addition of section 67.2300 altered the bill's original purpose, introduced a second subject to the bill, and rendered the bill's title unclear, thereby violating the single subject, clear title, and original purpose requirements of the Missouri Constitution. The court agreed, finding that the provisions of section 67.2300 did not fairly relate to or have a natural connection with the bill's general subject of "political subdivisions," but rather related to the completely different subject of homelessness. Consequently, the court declared TAFP HB 1606 invalid in its entirety. View "Byrd v. State of Missouri" on Justia Law

by
The Supreme Court of Missouri ruled in favor of three employees of a medical facility, Jayla Ruiz Morales, John Kimani, and Valarie Johnson, who were sued for wrongful death by the legal guardian of a patient, Ronald Scheer. Scheer, a resident at the St. Louis Developmental Disabilities Treatment Center-St. Charles Habilitation Center, died after his wheelchair's belt constricted his breathing. The employees were accused of failing to adequately supervise Scheer, failing to ensure that his wheelchair's seatbelt and pelvic harness were properly fastened, among other allegations. The employees argued that they were entitled to official immunity, a doctrine that protects public officials from liability for acts of negligence committed during the course of their official duties. The lower court rejected this argument and the employees sought a writ of prohibition from the Supreme Court of Missouri.The Supreme Court of Missouri held that the employees were entitled to official immunity. The court found that the tasks they were required to perform were not ministerial (routine or mundane tasks) but required discretion. Tasks such as checking on the patient, repositioning him, and using a seat belt and pelvic harness required the employees to use judgment to determine if Scheer needed additional care, and if so, what care to be administered. Therefore, these tasks were not ministerial and the employees were entitled to official immunity. The court made its preliminary writ of prohibition permanent, barring the lower court from taking further action in the case. View "State ex rel. Jayla Ruiz-Morales v. Alessi" on Justia Law

by
The Supreme Court of Missouri issued an opinion involving a dispute between Tyler Technologies, Inc., and several individual and corporate property owners. The property owners had filed a class-action petition alleging that Tyler Technologies negligently carried out its contractual obligations to assist Jackson County with the 2023 real property assessment. The property owners claimed that Tyler Technologies' failures resulted in some class members not receiving timely notice of increased assessments and others having their property assessments increase by more than 15 percent without a physical inspection.Tyler Technologies filed a motion to dismiss the allegations, arguing that the property owners failed to allege facts showing that Tyler Technologies owed them a duty of care. The circuit court overruled the motion to dismiss, prompting Tyler Technologies to file a petition for a writ of prohibition, which the Supreme Court of Missouri issued as a preliminary writ.After a review, the Supreme Court of Missouri determined that the property owners did not provide sufficient evidence to show that Tyler Technologies owed them a duty of care. The court noted that the duties the property owners described were statutory obligations of the county assessor, not private, third-party contractors like Tyler Technologies. The court also invoked the rule of privity, which generally states that a party to a contract does not owe a duty to a plaintiff who was not a party to the contract. In the court's view, disregarding this rule would expose Tyler Technologies to excessive and unlimited liability and potentially discourage contractors from entering into service contracts due to the fear of obligations and liabilities they would not voluntarily assume.Therefore, the Supreme Court of Missouri held that Tyler Technologies was entitled to dismissal of the disputed counts of the property owners' petition. The court made its preliminary writ of prohibition permanent, barring further action from the circuit court other than dismissing the contested counts with prejudice. View "State ex rel. Tyler Technologies, Inc. v. Chamberlain" on Justia Law

by
In Missouri, Jackson County and its public officials sought a writ of mandamus to overturn a circuit court's order which had denied their motion to dismiss a lawsuit brought by Jackson County property owners. The property owners alleged that the County had unlawfully increased assessed property values by failing to provide timely notice of increases and not conducting physical inspections for properties with increases of over 15%. The County argued that the property owners should have exhausted all available administrative remedies before filing the lawsuit.The Supreme Court of Missouri agreed with the County's argument, stating that the doctrine of exhaustion of administrative remedies requires an aggrieved party to seek available administrative remedies before courts will act. The court found that the County's failure to provide timely notice did not prevent the property owners from pursuing administrative remedies. At the time they filed the lawsuit, they could have exercised their appellate rights to the County's Board of Equalization or the State Tax Commission, but they chose not to. Therefore, the Supreme Court of Missouri held that because the property owners failed to exhaust all available administrative remedies before filing the lawsuit, the action must be dismissed, making permanent its preliminary writ of mandamus. View "State ex rel. Jackson County, Missouri v. Chamberlain" on Justia Law

by
The Supreme Court affirmed the final award of the labor and industrial relations commission affirming and adopting an administrative law judge's award of permanent total disability benefits to Jannie Harper under the Missouri Workers' Compensation Law, holding that the commission's decision was supported by competent and substantial evidence.Harper filed a claim for workers compensation against Springfield Rehab and Health Center and Premier Group Insurance Company Corvel Enterprise Company (collectively, Springfield Rehab). The commission awarded Harper permanent and total disability benefits, finding that Harper suffered a compensable injury arising from a workplace accident. The Supreme Court affirmed, holding that competent and substantial evidence supported the commission's final award of permanent total disability compensation and future medical care. View "Harper v. Springfield Rehab & Health Care Center" on Justia Law

by
The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission finding that Maryann Gray's applications for review were timely filed pursuant to Mo. Rev. Stat. 287.480 and overruling Hawthorn Children's Psychiatric Hospital's motion to strike, holding that the Commission did not err in finding that Gray's applications were timely filed.Gray, a registered nurse at Hawthorn, filed applications for review of the denial of her claims for injuries sustained during her employment. After a hearing, the Commission found Gray timely filed her applications and affirmed the denial of benefits as to a 2012 injury but ordered Hawthorn to pay Gray partial permanent disability benefits for 2013 and 2014 injuries. The Supreme Court affirmed, holding that the Commission did not err in finding that Gray's applications were timely filed under section 287.480. View "Gray v. Hawthorn Children's Psychiatric Hospital" on Justia Law