Justia Missouri Supreme Court Opinion Summaries

The Supreme Court made permanent its preliminary writ of prohibition prohibiting the circuit court from enforcing an order requiring Franklin County Prosecuting Attorney Matthew Becker and an associate prosecuting attorney, Matthew Houston, to appear and provide sworn testimony under oath at a pretrial motion hearing, holding that this case did not merit a presumption of vindictiveness.Defendant was indicted on two counts of first-degree murder and two counts of armed criminal action. After the State filed a notice of intent to seek the death penalty Defendant filed a motion to strike, alleging prosecutorial vindictiveness. The circuit court entered an order requiring Becker and Houston to appear and provide sworn testimony regarding Defendant's motion to strike. Becker filed a petition for a writ of prohibition seeking to prevent the circuit court from ordering him and Houston to provide sworn testimony. The Supreme Court issued a preliminary writ of prohibition. The Court then made permanent its writ of prohibition, holding (1) Defendant failed to allege sufficient facts to support a presumption of prosecutorial vindictiveness; and (2) the circuit court's order would cause irreparable harm by requiring Becker and Houston to divulge privileged work product. View "State ex rel. Becker v. Honorable Gael D. Wood" on Justia Law

In this action pleading claims for suit on account and account stated the Supreme Court reversed and vacated the judgment of the circuit court in favor of DiGregorio Food Products, Inc., holding that the circuit court erred in declaring the law in determining that Mo. Rev. Stat. 516.110(1)'s ten-year statute of limitations applied to the underlying claims.DiGregorio was an ingredient supplier for John Racanelli, who operated pizza restaurants. When Racanelli stopped making payments, DiGregorio ended its business relationship with Racanelli and his restaurants. DiGregorio later brought this action, asserting claims for suit on account and account stated. The circuit court declared that the ten-year statute of limitations contained in section 516.110(1) applied and that Racanelli was responsible for the amount of unpaid invoices as damages. The Supreme Court disagreed, holding (1) even assuming that DiGregorio proved its claims, this case was governed by the five-year statute of limitations contained in Mo. Rev. Stat. 516.120(1); and (2) therefore, DiGregorio's lawsuit was time barred. View "Di Gregorio Food Products, Inc. v. Racanelli" on Justia Law

The Supreme Court affirmed the judgment of the circuit court in favor of Boston Scientific Corporation (BSC) and C.R. Bard Inc. on Plaintiff's claims related to Defendants' design and manufacture of polypropylene mesh slings that were surgically implanted in Plaintiff, holding that any errors were not prejudicial.Specifically, the Supreme Court held (1) the circuit court did not err in excluding evidence of Bard's prior convictions; (2) the circuit court erred by not sustaining Plaintiff's objections to BSC's and Bard's use of her claims brought in the original petition against former defendants, but the errors were not prejudicial; and (3) the circuit court did not manifestly abuse its discretion in denying Plaintiff's request for a mistrial after Bard displayed to the jury prejudicial evidence of Plaintiff's settlements with the dismissed defendants. View "Sherrer v. Boston Scientific Corp." on Justia Law

The Supreme Court reversed Defendant's conviction of felony stealing, holding that because Defendant's conviction for felony stealing was not final when State v. Bazell, 497 S.W.3d 263 (Mo. banc 2016), was decided, Defendant was entitled to the benefit of its ruling at the time of his sentence.Defendant pled guilty to appropriating batteries and a battery charger worth at least $500. Imposition of sentence was suspended, and Defendant was placed on probation for five years. While Defendant was on probation, the Court decided Bazell. Thereafter, the circuit court revoked Defendant's probation and sentenced him to four years in prison. On appeal, Defendant argued that his offense constituted a misdemeanor pursuant to Bazell and he should be sentenced accordingly. The Supreme Court agreed, holding that the circuit court erred in overruling Defendant's objection and sentencing him for a class C felony when, under the Court's holding in Bazell, his offense was a class A misdemeanor. View "State v. Golden" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree attempted rape and other offenses, holding that the circuit court committed no error regarding the claims Defendant asserted on appeal.After a jury trial, Defendant was convicted of first-degree attempted rape, second-degree domestic assault, first-degree domestic assault, armed criminal action, and victim tampering. On appeal, Defendant raised five points challenging the circuit court's rulings admitting or excluding certain evidence. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion or plainly err in excluding the challenged evidence View "State v. Loper" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellants' request for injunctive and declaratory relief that allows all Missouri voters to vote by mail without having their signatures on their ballot envelopes acknowledged by a notary or other official authorized by law to administer oaths, holding that the request for relief was not supported or warranted by Missouri law.In the face of the ongoing public health crisis caused by the COVID-19 pandemic, the Missouri legislature expanded voting options for 2020 elections but put in place certain limitations on the newly created mail-in voting system. Appellants challenged one of those limitations - that absentee and mail-in ballot envelopes be notarized for certain voters. The circuit court denied relief. The Supreme Court affirmed, holding (1) the circuit court did not err in ruling that the plain and ordinary meaning of Mo. Rev. Stat. 115.277.1(2) does not allow Missouri voters who expect to confine themselves to avoid contracting the COVID-19 virus to vote absentee without notarization; and (2) where there is no constitutional right in Missouri to vote by absentee or mail-in ballot, Appellants' constitutional claims were without merit. View "Missouri State Conference of National Ass'n for Advancement of Colored People v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court reducing Plaintiff's personal injury award against Bi-State Development Agency (hereinafter, "Metro") to comply with the statutory cap set forth for public entities afforded sovereign immunity pursuant to Mo. Rev. Stat. 537.610, holding that there is no conflict between section 537.610 and Mo. Rev. Stat. 70.439's adopted federal regulations.Plaintiff was injured when a Metro Call-A-Ride bus collided with Plaintiff's school bus. The jury awarded Plaintiff $1.878 million in damages. Metro filed a motion for remittitur, asserting that the award should be reduced pursuant to section 537.610, which sets the liability limitations for public entities. The circuit court sustained the motion and reduced the damage award to the statutory maximum plus interest. On appeal, Plaintiff argued that section 537.610 conflicts with section 70.249 because the latter statute adopted specific federal regulations and was enacted after section 537.610. The Supreme Court affirmed, holding that there is no conflict between section 537.610's plain statutory language providing for a damages cap and section 70.439 providing that Metro needs to comply with federal safety regulations to receive state funding. View "Moore v. Bi-State Development Agency" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dissolving Wife's marriage to Husband and distributing the marital estate, holding that the circuit court did not err in awarding a marital 401(k) account of uncertain value to Husband.On appeal from the circuit court's apportionment of the marital estate, Wife argued that the circuit court legally erred and abused its discretion in awarding the 401(k) account to Husband in light of Husband's marital misconduct. The Supreme Court disagreed, holding that Wife did not carry her burden to show that the asset and debt division was unfair under the circumstances or that the circuit court committed reversible error. View "Lollar v. Lollar" on Justia Law

The Supreme Court vacated the judgment of the circuit court convicting Defendant of one count of robbery in the first degree, holding that the circuit court erred in excluding expert witness testimony regarding various factors that can impact the reliability of eyewitness identification.The case against Defendant was largely based on the identification provided by the victim at a "show up" that occurred minutes after the crime occurred. After the state rested its case, Defendant's counsel sought to have an expert witness testify about he factors that can impact the reliability of eyewitness identifications generally. The trial court excluded the expert testimony. On appeal, arguing that the circuit court erred in excluding the testimony. The Supreme Court agreed, holding (1) the exclusion of the expert testimony deprived Defendant of his opportunity to present expert evidence about the most important issue the jury had to decide - whether the victim's identification of Defendant was mistaken; and (2) the likelihood that the expert testimony would have altered the outcome was too high to affirm Defendant's conviction. View "State v. Carpenter" on Justia Law

The Supreme Court affirmed the order of the circuit court entering partial summary judgment in favor of Plaintiff on the issue of liability, holding that the circuit court did not err in entering summary judgment on the issue of liability in Plaintiff's favor.After he mobile home caught on fire Plaintiff sued several defendants, including Mehrdad Fotoohighiam, alleging that Fotoohighiam and the other defendants conspired to set her home on fire, causing her mental and physical harm and property damage. The circuit court entered partial summary judgment as to liability in Plaintiff's favor. After a jury trial on the issue of damages only the jury returned a verdict of $250,000 in actual damages and $2,500,000 in punitive damages. The Supreme Court affirmed, holding that the circuit court correctly determined that the uncontroverted material facts established Plaintiff's right to partial summary judgment on the issue of liability. View "Green v. Fotoohighiam" on Justia Law