Justia Missouri Supreme Court Opinion Summaries

The Supreme Court vacated the judgment of the circuit court granting summary judgment in favor of the Defendants and dismissing Plaintiffs' action seeking a declaratory judgment that Mo. Rev. Stat. 321.320 is an unconstitutional special law and that House Bill No. 1446 (HB 1446) violates the single-subject provision of the Missouri Constitution, holding that the circuit court erred.The City of De Soto and James Acres brought this action against the governor and the attorney general challenging section 321.320 and HB 1446. The De Soto Fire Protection District intervened as a defendant. The circuit court entered judgment for Defendants. The Supreme Court vacated the judgment below, holding that HB 1446 violates the prohibition against multiple subjects in Mo. Const. art. III, 23 and that the entire bill is invalid and may not be enforced. View "City of De Soto v. Parson" on Justia Law

The Supreme Court affirmed the circuit court's reduction of a damages award in favor of Appellant in a medical negligence case against University Physician Associates (UPA) and various physicians (collectively, the Physicians), holding that the circuit court did not err.Appellant filed this lawsuit alleging that the Physicians acted negligently in the Caesarean delivery of her child and in her postpartum care. The jury allocated 100 percent of fault to the Physicians and awarded $30,000 in past economic damages, $300,000 in past non-economic damages, and $700,000 in future non-economic damages. The circuit court concluded that Mo. Rev. Stat. 538.210.2(2)'s non-economic damages for catastrophic personal injury applied and reduced the non-economic damages award from $1 million to $748,828. The Supreme Court affirmed, holding (1) section 538.210's non-economic damage caps do not violate Mo. Const. art. I, 22(a); and (2) the Physicians' points on appeal lacked merit. View "Ordinola Velazquez v. University Physician Associates" on Justia Law

The Supreme Court affirmed in part and vacated in part the judgment of the circuit court rejecting Plaintiffs' claims challenging the refusal by the Department of Social Services (DSS) to provide MO HealthNet coverage, holding that the circuit court erred in declaring Mo. Const. art. IV, 36(c) constitutionally invalid.Plaintiffs, three Missourians eligible for MO HealthNet coverage under article IV, section 36(c), brought this action challenging the DSS's refusal to provide coverage on the grounds that the General Assembly failed to appropriate adequate funding. The circuit court rejected the claims, finding that the ballot initiative that enacted article IV, section 36(c) violated Mo. Const. art. III, 51, which prohibits initiatives from appropriating money without creating revenue to fund the initiative. The Supreme Court affirmed in part and vacated in part the circuit court's judgment, holding (1) article IV, section 36(c) does not appropriate money and does not remove the General Assembly's discretion in appropriating money to MO HealthNet; and (2) therefore, the circuit court erred in concluding that article IV, section 36(c) violates article III, section 51. View "Doyle v. Tidball" on Justia Law

The Supreme Court vacated the circuit court's judgment on the pleadings in favor of Governor Michael Parson and Michelle Hallford, the custodian of records for the governor's office (collectively, the Governor's Office) and dismissing the underlying lawsuit, holding that the Governor's Office was not entitled to judgment, as a matter of law, on the face of the pleadings. This lawsuit stemmed from two public records requests Plaintiff made under the Sunshine Law, Mo. Rev. Stat. 610.010-.035. Plaintiff argued that the Governor's Office violated the Sunshine Law when it required Plaintiff to prepay an estimate of costs for his first request, arbitrarily refused to waive fees associated with his first request, failed to explain its estimated delay in producing certain requested records, and impermissibly redacted certain records. The circuit court entered judgment on the pleadings in favor of the Governor's Office. The Supreme Court vacated the judgment, holding that the circuit court erred in sustaining the Governor's Office's motion for judgment on the pleadings as to several issues. View "Gross v. Parson" on Justia Law

The Supreme Court affirmed the judgment of the motion court overruling Appellant's Rule 24.035 amended motion seeking to set aside his guilty plea and vacate his judgment and sentence, holding that the motion court's findings of fact and conclusions of law were not clearly erroneous.Appellant pleaded guilty to first-degree involuntary manslaughter and armed criminal action and was sentenced to two consecutive terms of fifteen and twenty-five years' imprisonment. Appellant later filed a pro se Rule 24.035 to vacate, set aside, or correct the judgment and sentence. The motion court granted the motion, set aside Appellant's guilty plea, and reinstated his original charges. Thereafter, Appellant pled guilty to second-degree murder and armed criminal action and was sentenced to concurrent terms of life and thirty years' imprisonment. Appellant then filed a second Rule 24.035 motion. The motion court overruled the motion. The Supreme Court affirmed, holding that the motion court did not err. View "Staten v. State" on Justia Law

The Supreme Court reversed the judgment of the postconviction relief court overruling Appellant's Rule 24.035 motion for postconviction relief, holding that the mistaken belief held by Defendant regarding his sentencing, which arose from his plea counsel's direct assurance, resulted in his plea of guilty.After Defendant pleaded guilty to driving while intoxicated plea counsel advised him he would be eligible for long-term treatment under Mo. Rev. Stat. 217.362. The circuit court sentenced Defendant pursuant to that provision, but after sentencing, Defendant discovered he was statutorily ineligible for placement in the program. Defendant filed a motion to vacate, set aside or correct his judgment or sentence, arguing that his guilty plea was involuntary unknowing, and unintelligent. The postconviction relief court overruled the motion. The Supreme Court reversed, holding that prejudice existed and, therefore, the judgment overruling Defendant's motion was clearly erroneous. View "Hefley v. State" on Justia Law

The Supreme Court vacated the judgment of the circuit court in favor of Michael Holmes on his claim that the state legal expense fund (SLEF) was obligated to pay his 2016 judgment against two former officers of the St. Louis Metropolitan Police Department, holding that Holmes failed to show that he was entitled to a declaration that the State was obligated to pay his judgment out of SLEF.On appeal, the State argued that the circuit court erroneously applied the version of Mo. Rev. Stat. 105.726.3 in effect when the former police officers filed a false report that caused Holmes's wrongful arrest and conviction rather than the version in effect when Holmes filed his claim in a suit against the former officers. The Supreme Court vacated the judgment below, holding (1) a right to payment from SLEF does not arise until a claim is made, and therefore, section 105.726.3 governed Holmes's claim; and (2) SLEF was prohibited from paying any claim or judgment against the police officers. View "Holmes v. Steelman" on Justia Law

The Supreme Court made permanent a preliminary writ of prohibition it issued ordering the circuit court to take no other action in this wrongful death action other than to dismiss Sergeant Dirk Helms and Chief Joe Edwards of the De Soto Police Department, holding that the doctrine of official immunity prohibited Missouri courts from holding Helms and Edwards personally liable for any negligence.Plaintiff's daughter was a passenger in a vehicle who died during an automobile accident in the course of a police pursuant by Officer David Karssinger. Helms and Edwards filed separate motions to dismiss the claims against them, alleging that the claims were barred by official immunity and the public duty doctrine. After the circuit court overruled the motions Helms and Edwards sought this writ of prohibition. The Supreme Court granted the requested relief, holding that Helms and Edwards may have been negligent in failing to fulfill discretionary duties with due regard for the public safety and in such a way as to protect Plaintiff's daughter, but they were protected from liability by the doctrine of official immunity. View "State ex rel. Helms v. Honorable Joseph Alfred Rathert" on Justia Law

The Supreme Court affirmed the judgment of the circuit court declining to award Arrowhead Lake Estates Homeowners Association, Inc. attorney's fees after awarding Arrowhead Lake injunctive relief, holding that the circuit court did not abuse its discretion.Arrowhead Lake filed a petition for injunctive relief seeking to have an unapproved building removed and to be awarded attorney's fees. The circuit court ordered Homeowner to remove the unapproved building but did not award Arrowhead Lake attorney's fees. Arrowhead Lake appealed, arguing that it was entitled to attorney's fees based upon the language of the "Declaration of Covenants, Easements, and Restrictions of Arrowhead Lake Estates Subdivision." The Supreme Court affirmed, holding that where the Declaration's clear intent to provide recovery to a prevailing "lot owner" who brings suit to enforce the Declaration's terms and where Arrowhead Lake never claimed it was a "lot owner," the circuit court properly declined to award attorney's fees. View "Arrowhead Lake Estates Homeowners Ass'n, Inc. v. Aggarwal" on Justia Law

The Supreme Court affirmed in part and vacated in part the judgment of the circuit court awarding a class of Missouri corrections officers $113 million plus post-judgment interest for breach of contract, holding that the circuit court's determination that all preshift and postshift activities are compensable was erroneous.On appeal, the Missouri Department of Corrections (MDOC) argued that the circuit court erroneously determined that MDOC was liable on the corrections officers' breach of contract claims for time spent performing all preshift and postshift activities. The Supreme Court held (1) the circuit court erred in determining that all corrections officers' preshift and postshift activities were compensable principal activities that must be compensated; (2) because the award of damages and the court's declaratory and injunctive relief were based on the erroneous finding of liability, those rulings were erroneous; and (3) the circuit court correctly determined that MDOC must compensate corrections officers for time spent retrieving keys and radios and time spent monitoring and supervising offenders while not on post. View "Hootselle v. Missouri Department of Corrections" on Justia Law