Justia Missouri Supreme Court Opinion Summaries

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

The Supreme Court reversed the judgment of the circuit court affirming a jury's verdict in favor of Respondent on his legal malpractice claim, holding that public defenders are entitled to official immunity.Appellants were public defenders who were assigned to represent Respondent at his criminal trial. Appellant was found guilty. The Supreme Court later issued a writ of habeas corpus concluding that the circuit court lacked jurisdiction to prosecute Respondent. Respondent sued Appellants alleging legal malpractice and breach of fiduciary obligation for their failure to assert the jurisdictional challenge during their representation of him. The jury returned a verdict in Respondent's favor. Appellants filed a motion for judgment notwithstanding the verdict alleging that they were shielded from liability due to official immunity. The circuit court overruled the motion. The Supreme Court reversed, holding that public defenders have official immunity because they are public employees whose official statutory duties concern the performance of discretionary acts. View "Laughlin v. Perry" on Justia Law

The Supreme Court affirmed the judgment of the circuit court declaring section 11.800 of House Bill No. 2011 (HB2011) invalid, holding that there was a direct conflict between the language of Mo. Rev. Stat. 208.153.2 and 208.152.1(6), (12) requiring the MO HealthNet Division of the Missouri Department of Social Services to pay its authorized providers for covered physicians' services and family planning provided to Medicaid-eligible individuals and the language of section 11.800 prohibiting MO HealthNet from doing so.Planned Parenthood of the St. Louis Region and Reproductive Health Services of Planned Parenthood (Planned Parenthood) was an authorized provider of physicians' services and family planning because it had an agreement with MO HealthNet to do so. MO HealthNet informed Planned Parenthood that it could not reimburse Planned Parenthood for those services during the fiscal year 2019 due to section 11.800, which stated that "No funds shall be expended to any abortion facility...." The circuit court concluded that section 11.800 of HB2011 violated Mo. Const. Art. III, 23 because it amended substantive law. The Supreme Court affirmed, holding (1) section 11.800 was invalid because article III, section 23 prohibits using an appropriation bill to amend a substantive statute; and (2) the circuit court properly severed that provision from the remainder of HB2011. View "Planned Parenthood of St. Louis Region v. Department of Social Services, Division of Medical Services" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the circuit court dismissing Petitioners' petition for declaratory judgment and injunctive relief with respect to Missouri's absentee voting statute, Mo. Rev. Stat. 115.277, for failure to state a claim, holding that counts I, III, and IV of the petition stated claims upon which relief could be granted.In response to the COVID-19 pandemic and the upcoming August primary and November general elections, Petitioners filed a four-count petition seeking injunctive and declaratory relief to secure the ability to exercise their right to vote without leaving their homes to reduce the risk of contracting or spreading COVID-19 during the process. The Supreme Court sustained the State's motion to dismiss as to all counts. Petitioners appealed the dismissal of Counts I, III, and IV but abandoned their claim in Count II. The Supreme Court thus affirmed the circuit court's judgment with respect to Count II but reversed the remaining portions of the judgment, holding that Petitioners' claims plainly meet the pleading requirements for a declaratory judgment cause of action and the largely similar requirements for actions seeking injunctive relief. View "Missouri State Conference of National Association for Advancement of Colored People v. State" on Justia Law

The Supreme Court affirmed the decision of the clean water commission approving Trenton Farms' permit to establish a twin concentrated animal feeding operation (CAFO), holding that House Bill No. 1713 (HB 1713) does not violate the original purpose, single subject, or clear title requirements of the Missouri Constitution and that there was sufficient evidence regarding the CAFO's protection from a 100-year flood.The clean water commission affirmed the department of natural resource's issuance of a permit to Trenton Farms to establish a CAFO. Hickory Neighbors United, Inc. appealed, arguing (1) HB 1713, which amended Mo. Rev. Stat. 644.021.1 to change the criteria for members of the commission, violated Missouri Constitution article III's original purpose requirement and single subject and clear title requirements; and (2) there was insufficient evidence that CAFO's manure containment structures would be protected from inundation or damages in the event of a 100-year flood, a requirement of 10 C.S.R. 20-8.300. The Supreme Court affirmed, holding (1) HB 1713 is constitutionally valid; and (2) there was sufficient evidence that CAFO structures met regulatory requirements. View "In re Trenton Farms RE, LLC Permit No. MOGS10520" on Justia Law

In this wrongful death action, the Supreme Court affirmed the order of the circuit court granting summary judgment in favor of Mercy Hospital Joplin due to the expiration of the statute of limitations, holding that the circuit court properly dismissed Mercy Hospital.On appeal, Plaintiffs conceded that the statute of limitations had run prior to the filing of their claim against Mercy Hospital. Plaintiffs, however, argued that the one-year savings statute that applies to nonsuits applied in this case because they had taken nonsuit against Mercy Hospital less than one year before filing the instant action. The Supreme Court affirmed, holding (1) Plaintiffs did not suffer a nonsuit against Mercy Hospital but, rather, substituted Mercy Clinic, LLC under Rule 55.33(c) in place of Mercy Hospital even though the limitations period had already expired; (2) Plaintiffs' substitution of Mercy Clinic in place of Mercy Hospital was not a nonsuit entitling them to the benefit of the one-year savings provision; and (3) therefore, the action against Mercy Hospital was time barred. View "Sofia v. Dodson" on Justia Law