Justia Missouri Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court granting summary judgment in favor of Defendants and dismissing Plaintiffs' medical malpractice action, holding that the uncontested facts showed that Plaintiffs' medical malpractice action was time barred.On appeal, Plaintiffs argued that the circuit court erred because genuine issues of material fact existed as to whether their medical malpractice action was timely because the continuing care doctrine applied to toll the two-year statute of limitations. The Supreme Court rejected Plaintiffs' argument, holding that the uncontroverted material facts established that Plaintiffs' action was time barred. View "Newton v. Mercy Clinic East Communities" on Justia Law

The Supreme Court affirmed the judgment of the circuit court to the extent it enjoined the State from prohibiting unobtrusive picketing about matters of public concern in negotiations for a new labor agreement with the CWA Local 6360, holding that Mo. Rev. Stat. 105.585(2)'s prohibition against "picketing of any kind" is unconstitutional, but severance of the phrase renders the provision constitutional.The circuit court enjoined the State from enforcing or implementing section 105.585(2)'s mandated prohibition against "picketing of any kind" in negotiating a collective bargaining agreement with certain public employees. In so holding, the circuit court declared section 105.585(2) unconstitutional under both the state and federal constitutions as it relates to picketing. The Supreme Court affirmed, holding (1) section 105.585(2) violates Mo. Const. art. I, 8; (2) severance of the portion of the statute prohibiting "picketing of any kind" is applicable and appropriate; and (3) permanent injunction was the appropriate remedy in this case. View "Karney v. Department of Labor & Industrial Relations" on Justia Law

The Supreme Court issued a permanent writ of prohibition ordering the circuit court to vacate its order sustaining Father's amended motion for temporary custody of his minor child and awarding Father temporary custody of the child without a hearing, holding that the circuit court exceeded its authority by awarding temporary custody without first conducting a hearing.After Mother filed a petition for dissolution of marriage against Father the parties filed competing motions for temporary custody of their child. Without holding a hearing on the motions, the circuit court awarded temporary legal and physical custody of the child solely to Father. Mother filed a petition for a writ of prohibition, asserting that the circuit court acted in excess of its authority. The Supreme Court granted the writ, holding that, under the circumstances of this case, the circuit court exceeded its authority by awarding temporary custody without a hearing. View "State ex rel. Koehler v. Honorable Midkiff" on Justia Law

The Supreme Court dismissed Appellant's appeal challenging his convictions for first-degree statutory sodomy and attempted first-degree statutory sodomy, holding that, because two counts as to which the jury could not reach of verdict remained pending, the circuit court's judgment was not final.A jury convicted Appellant of the two sodomy charges but could not reach a verdict on the charges for first-degree statutory rape and incest. The circuit court declared a mistrial as to the rape and incest charges. The court then entered a judgment disposing of and imposing sentences on the two sodomy charges. The judgment, however, was silent as to the two counts on which the court had ordered a mistrial. Appellant appealed. The Supreme Court dismissed the appeal, holding that because Appellant was charged with four counts and two of those counts remained pending before the circuit court, the court's judgment of conviction on only two of the counts was not final for purposes of appeal. View "State v. Waters" on Justia Law

The Supreme Court affirmed the decision of the Administrative Hearing Commission determining that DI Supply I, LLC's room furnishing sales to the Drury Hotels were not exempt from sales tax under the resale exemption in Mo. Rev. Stat. 144.010.1(11), holding that DI Supply failed to meet its burden to prove that the items it sold to Drury Hotels were resold by the hotels.An audit determined that DI Supply failed to remit sales tax on more than $11 million in taxable sales of room furnishings to Drury Hotels during the audit period. DI Supply contested the tax liability, arguing that the items of tangible personal property were purchased for resale to hotel guests and not subject to Missouri local sales or use tax. The Commission upheld $613,159 of the assessment for sales tax and interest. On appeal, DI Supply contested its sales tax liability for sales of room furnishings to Drury Hotels. The Supreme Court affirmed, holding that DI Supply failed to show that Drury Hotels transferred title or ownership of the room furnishings and, therefore, failed to show the applicability of the resale exemption by clear and unequivocal proof. View "DI Supply I, LLC v. Director of Revenue" on Justia Law

The Supreme Court affirmed the judgment of the circuit court finding that the petition filed by a trust's sole beneficiary seeking removal of the trustee violated the trust's no-contest clause and in entering summary judgment in the trustee's favor on its declaratory judgment claim, holding that the no-contest clause in the trust document was enforceable.After the beneficiary in this case stopped receiving distributions from the trust, he filed suit against the trustee for removal of the trustee and breach of trust. The trustee filed a counterclaim seeking a judgment declaring that the petition violated the trust instrument's no-contest clause and thus canceled and revoked all trust provisions in the beneficiary's favor. The circuit court sustained the motion for summary judgment on the trustee's counterclaim. The Supreme Court affirmed, holding that because the beneficiary did not seek relief form the no-contest clause pursuant to Mo. Rev. Stat. 456.4-420 and instead filed a petition asserting the claims the settlor unambiguously stated would forfeit the beneficiary's interest in the trust, the circuit court properly found the petition violated the trust's no-contest clause. View "Knopik v. Shelby Investments, LLC" on Justia Law

The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission denying Appellant's claim for workers' compensation benefits for injuries she suffered when she fell while entering her workplace, holding that Appellant failed to prove that her injury arose out of and in the course of her employment.An administrative law judge denied Appellant any workers' compensation benefits, concluding that Appellant did not meet her burden of showing that her fall was the prevailing factor causing the conditions of which she complained. The Commission affirmed, holding that Appellant failed to establish that her injury arose out of her employment. The Supreme Court affirmed, holding that Appellant's claim was noncompensable because she failed to prove her injury arose out of and in the course of her employment because the hazard or risk involved was one Appellant was equally exposed to in her regular, nonemployment life. View "Annayeva v. SAB of the TSD of the City of St. Louis" on Justia Law

The Supreme Court affirmed the decision of the labor and industrial relations commission denying Claimants' claim for enhanced mesothelioma benefits under Mo. Rev. Stat. 287.200.4(3)(a), holding that because the deceased employee's employer (Employer) did not "elect to accept mesothelioma liability," Claimants were not entitled to the enhanced benefit.The decedent died from mesothelioma cause by toxic exposure to asbestos during his employment with Employer. Prior to his death, Claimants filed a claim for workers' compensation benefits and specifically sought enhanced benefits under subdivision 287.200.4(3)(a). An administrative law judge denied the claim. The commission affirmed the denial of the enhanced benefit, concluding that an employer that ceased operations sixteen years before section 287.200.4(3)(a) took effect could not have elected to accept enhanced liability under that section. The Supreme Court affirmed, holding that Claimants were not entitled to the enhanced benefit because Employer did not affirmatively elect to accept liability for the enhanced benefit as required under statute. View "Hegger v. Valley Farm Dairy Co." on Justia Law

The Supreme Court affirmed the judgment of the circuit court sustaining the chairman of the Missouri board of probation and parole's motion to dismiss Appellant's petition for declaratory judgment in which he sought a declaration of his right to a parole hearing, holding that the repeal of Mo. Rev. Stat. 195.295.3 did not render Appellant parole eligible.In 2013, a jury found Appellant guilty of drug trafficking in the second degree for acts committed in 2009. Defendant was sentenced under section 195.295.3 as a prior drug offender to a term of imprisonment without eligibility for parole. After the general assembly repealed section 195.295 in January 2017, Appellant filed his petition for declaratory judgment arguing he was eligible for parole because the statute that had rendered him parole ineligible had been repealed. The circuit court dismissed the petition, concluding that the repeal of the statute could not be applied retroactively because it would alter Appellant's sentence. The Supreme Court affirmed, holding that because Appellant's parole ineligibility was part of his sentence, the repeal of section 195.295.3 did not render him eligible for parole. View "Mitchell v. Phillips" on Justia Law

The Supreme Court reversed the judgment of the circuit court sustaining Respondent's motion for judgment on the pleadings and granting Respondent a hearing on his single-count petition for declaratory judgment claiming his parole eligibility should no longer be governed by Mo. Rev. Stat. 195.295 and releasing Respondent on parole, holding that the repeal of section 195.295 had no effect on Respondent's parole eligibility.Respondent was found guilty of trafficking drugs in the second degree for acts committed in May 2006. Respondent was sentenced as a prior drug offender to twenty-five years' imprisonment without eligibility for parole under section 195.295. On January 1, 2017, section 195.295 was repealed. At issue was the legal effect section 195.295's repeal had on Respondent's eligibility for parole. The Supreme Court held that, for the reasons set forth in Mitchell v. Jones, __ S.W.3d __, also decided today, Respondent was not eligible for parole. View "Woods v. Missouri Department of Corrections" on Justia Law