Justia Missouri Supreme Court Opinion Summaries

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

The Supreme Court reversed the judgment of the circuit court against Defendant for one count of class C felony stealing and two counts of class A misdemeanor stealing, holding that absent proof of value, the offense submitted was a class D misdemeanor, not a class A misdemeanor, and that the circuit court should have entered judgment against Defendant for a class D felony rather than a class C felony.The jury instructions in this case required the jury to find Defendant retained the two victims' personal items without their consent and with the purpose of withholding this property from them. At trial, the State did not present evidence of the value of the stolen items of personal property. At issue on appeal was whether the circuit court properly entered judgment for one count of class C felony and two counts of class A misdemeanor stealing. The Supreme Court remanded the case, holding that the circuit court should have entered judgment for one count of class D felony stealing and two counts of class D misdemeanor stealing. View "State v. Knox" on Justia Law

The Supreme Court made permanent its preliminary writ of prohibition prohibiting the circuit court from ordering certain defendants to be joined as necessary parties, holding that Mo. R. Civ. P. 52.04(a) did not mandate that the added defendants be joined.After deficiencies in the construction of an independent senior living facility (the Project) were discovered, Plaintiff brought contract and tort claims against the architect, the structural engineer, the construction company, the framer, and the supplier, alleging construction defects. The masonry company hired to perform brick masonry work was not included as a defendant. Certain defendants moved to add the masonry company, arguing that the company must be added pursuant to Rule 52.04. The circuit court ordered the masonry company be joined. Plaintiff filed a petition for a writ of prohibition seeking to direct the circuit court to dismiss and remove the masonry company. The court of appeals denied the petition. The Supreme Court granted the petition, holding that the masonry company was not a "necessary" defendant, and therefore, the circuit court did not have the authority to require joinder. View "State ex rel. Woodco, Inc. v. Honorable Jennifer Phillips" on Justia Law

The Supreme Court granted Petitioner's petition for a writ of habeas corpus, holding that Petitioner should have been discharged from probation before the State attempted to revoke probation and the circuit court suspended and revoked his probation.In his petition, Petitioner alleged that his due process rights were violated when, rather than discharging him from probation, the circuit court revoked his probation and ordered his sentence executed despite his having sufficient earned compliance credits (ECCs) and having paid restitution in full. The Supreme Court granted habeas relief and ordered that Petitioner be discharged from the custody of the Missouri Department of Corrections, holding that the circuit court no longer had authority to revoke Petitioner's probation after he paid restitution because the combination of his time served on probation and accrued ECCs would have entitled him to discharge under Mo. Rev. Stat. 217.703.7. View "State ex rel. Jonas v. Minor" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of second-degree domestic assault and armed criminal action, holding that none of Defendant's allegations of error entitled Defendant to relief.Specifically, the Supreme Court held (1) the circuit court's failure to strike for cause a juror because she was the sister of an assistant prosecuting attorney who participated in Defendant's case did not result in manifest injustice; (2) the circuit court did not commit plain error in instructing the jury on self-defense; (3) the circuit court's response to the jury's question regarding the mental state for domestic assault did not warrant relief under plain error review; (4) the circuit court did not abuse its discretion in excluding the testimony of a defense witness about the victim's "reputation" for violence; and (5) Defendant was not entitled to relief due to the circuit court overruling his objection to certain testimony. View "State v. Brandolese" on Justia Law

The Supreme Court made permanent its preliminary writ of mandamus compelling the circuit court to transfer the underlying lawsuit to St. Charles County, holding that the circuit court had no authority to change venue and transfer the case from St. Charles County to St. Louis County.Universal Credit Acceptance, Inc. (UCA) filed the underlying lawsuit in St. Charles County seeking to recover a judgment arising from Renwick Ware's alleged default on a retail sales installment contract. After the associate circuit division sustained Ware's application for change of judge, Ware filed a motion to change the venue to St. Louis County. The circuit court sustained the motion and transferred the case to St. Louis County. UCA filed a petition for a writ of mandamus, arguing that, pursuant to Rule 51.06(a), Ware waived the right to file a motion to change venue because the motion was not consolidated with his application for change of judge. The Supreme Court issued a preliminary writ that it made permanent, holding that Ware's motion to change venue was improper under Rule 51.06(a), and therefore, UCA demonstrated a clear and unequivocal right to have the case retransferred to St. Charles County. View "State ex rel. Universal Credit Acceptance, Inc. v. Honorable Reno" on Justia Law