Justia Missouri Supreme Court Opinion Summaries

The Supreme Court made permanent a preliminary writ sought by LG Chem, Ltd. to prohibit the circuit court from enforcing its over overruling LG Chem's motion to dismiss for lack of personal jurisdiction, holding that due process prohibited Missouri courts from asserting personal jurisdiction over LG Chem in this matter.LG Chem, a Korean company with its headquarters in Seoul, South Korea, manufactured model 18650 lithium-ion batteries. Peter Bishop sued LG Chem in the St. Louis County circuit court alleging that he purchased one of LG Chem's batteries in a store located in St. Peters, Missouri for use in his e-cigarette. Bishop alleged that the battery spontaneously exploded in his pocket, resulting in burn injuries. LG filed a motion to dismiss for lack of personal jurisdiction. The circuit court overruled the motion on the merits. LG then sought a writ of prohibition. The Supreme Court issued a preliminary writ of prohibition. The Court then made its preliminary writ permanent with directions to the circuit court to vacate its order overruling LG Chem's motion to dismiss for lack of personal jurisdiction, holding that LG Chem lacked sufficient minimum contacts with the state of Missouri, and therefore, the assertion of personal jurisdiction over LG Chem would violate due process. View "State ex rel. LG Chem, Ltd. v. Honorable McLaughlin" on Justia Law

In this disability discrimination action, the Supreme Court reversed the award of litigation expenses but affirmed in all other respects the circuit court's judgment in favor of Plaintiff, holding that no statute allows a circuit court to award as litigation expenses the expenses incurred by counsel for the prevailing party in a Missouri Human Rights Act (MHRA) case.Plaintiff sued the City of Kansas City for disability discrimination and retaliation under the MHRA. The jury returned a verdict in Plaintiff's favor, awarding him actual and punitive damages. The circuit court entered judgment in conformity with the verdict. Upon Plaintiff's motion, the circuit court amended the judgment to award attorney fees and litigation expenses. The Supreme Court affirmed in part and reversed in part, holding (1) the City's argument that the circuit court erred in admitting evidence and argument of Plaintiff's workers' compensation permanent partial disability rating was not preserved for appellate review; and (2) the circuit court erred in awarding Plaintiff litigation expenses because no statute authorizes an award of litigation expenses in an MHRA case. View "Wilson v. City of Kansas City" on Justia Law

The Supreme Court affirmed the judgment of the circuit court on a jury verdict for Plaintiff on her claim that, as directors of the closely held Perma-Jack Company, Defendants breached their fiduciary duty to Plaintiff as a shareholder, holding that the circuit court did not abuse its discretion.Specifically, the Supreme Court held (1) with respect to Plaintiff's breach of fiduciary claim, because Plaintiff did not sue Perma-Jack itself for lost wages or reinstatement, Plaintiff's claim was not actually one for wrongful termination, as Defendants argued; (2) the circuit court did not err in finding that Defendants engaged in shareholder oppression and ordering Defendants to buy Plaintiff's Perma-Jack shares; and (3) the circuit court did not abuse its discretion in determining the fair value of Plaintiff's shares and in denying Plaintiff prejudgment interest and attorney's fees. View "Robinson v. Langenbach" on Justia Law

The Supreme Court affirmed the judgment of the circuit court finding that Fredric Prater was liable for $20,000 in damages after a car accident with Denise Kappel, holding that the circuit court did not abuse its discretion in admitting photographs of the rental car Kappel was driving at the time of the accident.Denise was at a stop when Prater drove into her rental car from behind. Denise and her husband (the Kappels) sued Prater for negligence. At trial, the circuit court admitting into evidence, over the Kappels' objection, photographs showing the post-accident damage to the front of his car and the rear of the rental car Denise was driving. The jury found Prater liable for negligence and awarded $20,000 in damages, significantly less than the $650,000 the Kappels sought. The Kappels appealed, arguing that the photographs should not have been admitted because their quality was too low and because there was no expert evidence connecting the amount of damage to Denise's vehicle to the issue of whether the collision caused the injuries she claimed. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in admitting the photographs. View "Kappel v. Prater" on Justia Law

The Supreme Court vacated the judgment of the motion court overruling Appellant's pro se Rule 29.15 postconviction motion seeking to vacate his felony statutory sodomy conviction under Mo. Rev. Stat. 566.062, holding that there was no final judgment in the underlying criminal case, and therefore, Appellant's postconviction relief motion was premature.In his motion for postconviction relief, Appellant argued that he received ineffective assistance of trial counsel. After an evidentiary hearing, the motion court overruled the motion on the merits. Appellant appealed, arguing that his postconviction relief motion was premature because the trial court failed to carry out the Supreme Court's mandate issued in his direct appeal, and therefore, his judgment of conviction was not yet final. The Supreme Court agreed, holding (1) the trial court failure strictly to comply with the Court's mandate; and (2) therefore, the judgment of condition in Appellant's criminal case was not yet a final judgment that triggers the running of the time period in which he can file a Rule 29.15 motion, and the Rule 29.15 motion was premature. View "Lemasters v. State" on Justia Law

The Supreme Court reversed the judgment of the circuit court overruling Appellant's Rule 24.035 motion for postconviction relief from the sentences imposed on her for class C felony stealing under Mo. Rev. Stat. 570.030, holding that Appellant's crimes were class A misdemeanors under State v. Bazell, 497 S.W.3d 263 (Mo. banc 2016), and Appellant should have been sentenced accordingly.Appellant's judgment of conviction was not yet final when the Supreme Court decided Bazell, which held that stealing in violation of section 570.030 is a class A misdemeanor that cannot be enhanced to a class C felony. After Bazell was decided, Appellant's two five-year sentences were imposed. Appellant argued that she was entitled to have Bazell applied to her sentencing and that the sentences imposed exceeded the sentences authorized by law. The Supreme Court agreed, holding (1) Appellant was entitled to have Bazell applied to her sentencing; and (2) therefore, the circuit court erred in entering judgments of conviction against Appellant and sentencing her as if her crimes were class C felonies. View "Hamilton v. State" on Justia Law

The Supreme Court reversed the judgment of the circuit court sentencing Appellant for class C felony stealing under Mo. Rev. Stat. 570.030 because State v. Bazell, 497 S.W.3d 263 (Mo. banc 2016), held that stealing in violation of section 570.030 is a class A misdemeanor that cannot be enhanced to a felony.Appellant pleaded guilty to stealing in violation of section 570.030. Before Appellant's sentencing occurred Bazell was decided. Bazell held that stealing under section 570.030.1 was a class A misdemeanor that could not be enhanced to a class C felony. The circuit court subsequently sentenced Appellant to seven years for a class C felony, despite Appellant's objection that Bazell required he be sentenced for a class A misdemeanor. In his direct appeal, Appellant argued that he received an excessive sentence. The Supreme Court agreed, holding (1) Appellant did not waive his claim that he received an excessive sentence; and (2) the circuit court erred in sentencing Appellant for a class C felony. View "State v. Russell" on Justia Law

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