Justia Missouri Supreme Court Opinion Summaries

The Supreme Court denied Petitioner's petition for a writ of habeas corpus, holding that Petitioner's claims of actual innocence did not entitle him to relief and that Petitioner neither demonstrated the "substantial threshold showing of insanity" nor that he was incompetent under Mo. Rev. Stat. 552.060.Petitioner was convicted of murder and sentenced to death. After the Supreme Court issued its order setting Petitioner's execution date, Petitioner filed his petition for writ of habeas corpus. The Supreme Court denied relief, holding (1) Petitioner failed to prove the substantial threshold showing of insanity required by Panetti v. Quarterman, 551 U.S. 930 (2007) and Ford v. Wainwright, 477 U.S. 399 (1986); (2) Petitioner failed to prove that he is incompetent under section 552.060; and (3) Petitioner failed to offer sufficient evidence to show actual innocence, either as a gateway or as a freestanding claim. View "State ex rel. Barton v. Stange" on Justia Law

The Supreme Court affirmed the judgment of the circuit court judgment overruling Defendant's Mo. Rev. Stat. 29.15 motion for postconviction relief from his death sentence for first degree murder, holding that the circuit court's findings of fact and conclusions of law were not clearly erroneous.On appeal, Defendant argued that the circuit court committed multiple errors affecting the guilt phase, penalty phase, and postconviction relief phases of his criminal case. Among other things, Defendant argued that the circuit court erred in failing to find that his counsel provided ineffective assistance in several respects. The Supreme Court affirmed, holding that the circuit court's findings of fact and conclusions of law were not clearly erroneous and that the circuit court did not err in denying postconviction relief. View "McFadden v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court committing Appellant to the department of mental health (DMH) as a sexually violent predator (SVP), holding that the circuit court did not err.In 2005, Appellant pleaded guilty to felony sex abuse. Before his release in 2016, the State filed a petition seeking to civilly commit him as an SVP. A jury found Appellant to be an SVP and the circuit court committed him to DMH. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion when it prohibited Appellant from questioning the jury panel about the specific ages of child victims; (2) the circuit court did not err when it excluded a portion of the testimony regarding Appellant's risk of future dangerousness; (3) the circuit court did not plainly err in submitting Instruction No. 6, the verdict director; (4) Appellant received effective assistance of counsel at his probable cause hearing; (5) the circuit court did not plainly err in overruling Appellant's motion for new trial based on juror nondisclosure of bias; (6) Appellant's claim of ineffective assistance of counsel for failure to move for change of venue was without merit; and (7) omissions in the trial transcript did not prejudice Appellant's appellate review. View "In re Care & Treatment of D.N." on Justia Law

The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission denying Employee's workers' compensation benefits on the grounds that she failed to prove her work injury was the prevailing or primary factor causing any permanent disability and denying Employee's claim against the Second Injury Fund as moot, holding that the Commission did not err.Employee was exposed to cypermethrin, an insecticide, while working for Employer. When Employee was at the doctor's office for testing, another patient's dog got loose and tripped Employee. Employee fell and allegedly sustained permanent injuries to her knees, lower back, hip and neck. Employee filed a claim for workers' compensation asserting that, in addition to cypermethrin exposure, she sustained injuries from being tripped while walking out of the doctor's office. An ALJ awarded Employee benefits. The Commission reversed, concluding that Employee failed to meet her burden of proving her exposure to cypermethrin was the prevailing or primary factor in causing any alleged injury from being tripped accidentally. The Supreme Court affirmed, holding (1) Employee was not entitled to workers' compensation for any injury sustained from her accidental tripping; and (2) because Employee's accidental tripping did not arise out of and in the course of her employment, the Fund was not implicated. View "Schoen v. Mid-Missouri Mental Health Center" on Justia Law

The Supreme Court affirmed the judgment of the circuit court sentencing Defendant to two terms of life imprisonment without the possibility of parole, holding that Mo. Rev. Stat. 565.020 is constitutional as applied to Defendant.Defendant was nineteen years old when he killed his grandparents. Defendant was convicted of two counts of first-degree murder and sentenced to death for each murder count. Later, a federal district court ordered the state of Missouri either to sentence Defendant to life without the possibility of probation or parole or grant him a new penalty phase trial. On remand, Defendant argued that section 565.020, which then provided that first-degree murder shall be punishable either by death or imprisonment for life without eligibility for probation or parole, was unconstitutional as applied to him because offenders who commit crimes at nineteen years old also display the transient, hallmark features of adolescence affecting risk and impulse control. The circuit court rejected Defendant's claims and sentenced him to life without the possibility of parole on both murder counts. The Supreme Court affirmed, holding that where Supreme Court precedent clearly defines a juvenile as an individual younger that eighteen years of age for purposes of the considerations Defendant sought, section 565.020 was constitutional as applied to Defendant. View "State v. Barnett" on Justia Law

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