Justia Missouri Supreme Court Opinion Summaries

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After the court of appeals dismissed Appellant's appeal from the circuit court's order overruling its motion, the Supreme Court retransferred this case to the court of appeals to review the underlying merits of the circuit court's order as asserted in Appellant's remaining points on appeal, holding that the circuit court's order was appealable and did not have to be denominated a judgment for an appeal to be taken. The motion at issue was Appellant's "Motion for Order Revoking, or in the Alternative, Modifying and Changing Interlocutory Order Appointing Receiver." The circuit court overruled the motion. The court of appeals dismissed Appellant's appeal because the order was not denominated a judgment pursuant to Rule 74.01(a). The Supreme Court retransferred the case, holding (1) the circuit court's order was appealable pursuant to Mo. Rev. Stat. 515.665 and 512.020(2); and (2) the circuit court's order did not need to be denominated a judgment under Rule 74.01(a) for an appeal to be taken because it was an interlocutory order that did not fully resolve at least one claim and did not establish all of the rights and liabilities of the parties with respect to that claim. View "Meadowfresh Solutions USA, LLC v. Maple Grove Farms, LLC" on Justia Law

Posted in: Civil Procedure
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The Supreme Court vacated the judgment of the circuit court convicting Defendant of first-degree assault and armed criminal action, holding that the circuit court erred in failing to submit a self-defense instruction. On appeal, Defendant argued that the circuit court erred by refusing to submit a self-defense instruction. In response, the State argued that Defendant was not entitled to a self-defense instruction because Defendant denied stabbing the victim. The Supreme Court disagreed with the State, holding (1) the only relevant inquiry when a defendant requests an instruction on a theory of defense is whether, after viewing all the evidence and drawing all reasonable inferences in favor of the theory propounded by the defendant, there was substantial evidence to support the requested instruction; and (2) the circuit court erred in failing to give a self-defense instruction because there was substantial evidence to support the submission of such an instruction. View "State v. Barnett" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the circuit court finding Defendant guilty of the first-degree murder of a ten-year-old girl and sentencing him to death, holding that none of Defendant's assignments of error warranted reversal. Specifically, the Court held that the circuit court did not abuse its discretion by (1) overruling Defendant's objection to the admission of photographs from the victim's cellphone; (2) admitting gun evidence found in Defendant's home; (3) admitting the contents of a folder containing photos of Defendant's female, middle school students and accounts of fictional sexual encounters with thirteen-year-old girls; (4) admitting victim impact evidence; (5) permitting the State to argue during closing argument that the jury could speak for the victim and her family by sentencing Defendant to death; and (6) sustaining the State's motion to strike a venire person for cause during the death qualification voir dire. Further, Defendant's constitutional arguments were unavailing, and Defendant's death sentence met all the statutory requirements. View "State v. Wood" on Justia Law

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The Supreme Court made permanent a preliminary writ of prohibition it issued directing the circuit court to dismiss Plaintiff's claims against Relators for lack of personal jurisdiction, holding that Plaintiff failed to show that Relators were "at home" in Missouri and failed to identify any conduct by Relators in Missouri out of which Plaintiff's claims arose. Plaintiff filed suit against Relators, Kansas business entities, alleging personal injury sustained while working at an apartment complex in Kansas. Relators sought a writ of prohibition on the ground that the circuit court lacked personal jurisdiction over them. The court of appeals overruled the motion. Relators then petitioned the Supreme Court for the same relief. The Supreme Court granted relief, holding (1) Relators were not "at home" in Missouri to such an extent that they were subject to the general jurisdiction of Missouri courts; and (2) Relators' contacts with Missouri were not sufficient to create general or specific jurisdiction on their own. View "State ex rel. Cedar Crest Apartments, LLC v. Honorable Jack Grate" on Justia Law

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The Supreme Court affirmed the judgment of the motion court accepting Defendant's guilty plea to first-degree murder, first-degree robbery, and armed criminal action and sentencing him to life imprisonment without the possibility of parole, holding that Defendant's counsel was effective and that Defendant's plea was entered knowingly and voluntarily. After the circuit court imposed the sentence Defendant filed a motion for postconviction relief alleging, among other things, that his counsel was ineffective, and therefore, his plea was not entered knowingly and voluntarily. The Supreme Court affirmed, holding (1) Defendant was not coerced into accepting the State's plea agreement; (2) Defendant was competent to plead guilty; and (3) counsel was not ineffective for declining to seek a second competency examination. View "Johnson v. State" on Justia Law

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The Supreme Court reversed the decision of the Administrative Hearing Commission (AHC) assessing use tax, additions to tax, and interest against Appellants, Business Aviation LLC and its members, as a result of Business Aviation's purchase of an aircraft, holding that Appellants qualified for the resale use tax exemption pursuant to the interplay of Mo. Rev. Stat. 144.018.1(4), 144.615(3), and 144.030.2(20). The aircraft at issue was purchased in Kansas and then leased by Business Aviation to Burgess Aircraft Management LLC, a common carrier in Missouri. The AHC determined that Appellants owed the use tax because, although it found that the right to use the aircraft was transferred to Burgess, the right was not fully transferred for valuable consideration. The Supreme Court reversed, holding that because Business Aviation transferred the right to use the aircraft to a common carrier for valuable consideration paid or to be paid, the lease agreement constituted a sale pursuant to both the use and sales tax definitions. View "Business Aviation, LLC v. Director of Revenue" on Justia Law

Posted in: Tax Law
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The Supreme Court affirmed the judgment of the circuit court dismissing the petition filed by the Missouri Coalition for the Environment and one of its members (collectively, the Coalition) seeking a declaratory judgment and injunctive relief against the State and the Clean Water Commission, holding that the Commission lacked standing. In its petition, the Coalition challenged the validity of Mo. Rev. Stat. 644.021, as amended by House Bill No. 1713. The State filed a motion to dismiss, asserting that the Coalition did not have taxpayer standing. The Coalition conceded that it had not shown taxpayer standing but argued that it had standing pursuant to Mo. Rev. Stat. 516.500. The circuit court dismissed the petition with prejudice for lack of standing. The Supreme Court affirmed, holding that section 516.500 did not provide standing to the Coalition nor did it eliminate the requirement that the Coalition have standing to bring this action. View "Missouri Coalition for Environment v. State" on Justia Law

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In this appeal from the circuit court's distribution of proceeds from Nicklaus Macke's wrongful death settlement the Supreme Court affirmed the judgment of the circuit court overruling Appellant's motion for a second continuance and in apportioning only a small percent of the wrongful death settlement to Appellant, holding that the circuit court did not err or abuse its discretion. Nicklaus, the son of Pamela Eden and Loren Macke (Macke), suffered fatal injuries in a motor vehicle collision with Austin Patton. Macke negotiated a settlement with Patton's insurance company, which offered to pay its policy limit in satisfaction of Macke's wrongful death claim against Patton. The circuit court apportioned ninety-eight percent of the settlement to Nicklaus' father and two percent to Eden, who played little to no role in Nicklaus' childhood and upbringing. The Supreme Court affirmed, holding (1) the circuit court did not err in overruling Appellant's motion for continuance; and (2) the circuit court did not erroneously apply the law in making its apportionment judgment, and the apportionment was not against the weight of the evidence. View "Macke v. Patton" on Justia Law

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The Supreme Court reversed the decision of the administrative hearing commission (AHC) reversing the denial of the director of the department of revenue of David and Jill Kehlenbrinks' application for a sales tax refund, holding that the AHC erroneously decided that the Kehlenbrinks were entitled to a refund of all the sales tax they paid after their purchase of a new vehicle. On appeal, the director claimed that, in calculating the sales tax owed on the Kehlenbrinks' newly purchased vehicle, Mo. Rev. Stat. 144.025.1 allowed the Kehlenbrinks to credit the sale proceeds of only one vehicle against the purchase price of the new vehicle. The Supreme Court agreed, holding that the AHC erroneously decided that the Kehlenbrinks were entitled to a refund of all the sales tax they paid because it mistakenly allowed credit for four vehicles the Kehlenbrinks sold within 180 days of their purchase of a new vehicle. View "Kehlenbrink v. Director of Revenue" on Justia Law

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The Supreme Court made permanent in part and quashed in part a preliminary writ it issued in response to Brad Halsey's petition seeking to direct Respondent, the Honorable Jennifer M. Phillips, to dismiss Jennifer Dachenhausen's claims against him, holding that Dachenhausen's assault and battery claims were time-barred but her emotional distress counts properly alleged claims independent from traditional common law actions. Dachenhausen filed suit against Halsey for assault, battery, intentional infliction of emotional distress, and negligent infliction of emotional distress. Halsey filed a motion to dismiss, arguing that Dachenhausen's claims were time-barred. Respondent overruled Halsey's motion to dismiss. Halsey then petitioned the Supreme Court for a writ of prohibition. The Supreme Court granted it in part, holding (1) the face of Dachenhausen's petition demonstrated that the statute of limitations had run on her assault and battery claims; and (2) the petition did not affirmatively show that Dachenhausen's claims for negligent and intentional infliction of emotional distress were time-barred. View "State ex rel. Halsey v. Honorable Jennifer M. Phillips" on Justia Law

Posted in: Personal Injury