Justia Missouri Supreme Court Opinion Summaries

The Supreme Court vacated Defendant's guilty by mental disease or defect (NGRI) plea that the circuit court accepted after finding Defendant lacked competence to continue with the criminal proceedings, holding that the circuit court exceeded its authority under Mo. Rev. Stat. 552.020.8 and violated Defendant's due process rights.Defendant was charged with first-degree robbery and armed criminal action. After accepting Defendant's NGRI plea the circuit court found Defendant lacked competence to proceed and committed him to the department of mental health. The Defendant sought a writ of habeas corpus arguing that, pursuant to section 552.020.8, upon finding him incompetent, the circuit court was required to suspend the proceedings and commit him to the department of mental health. The Supreme Court agreed, holding that, by accepting Defendant's NGRI plea despite finding him incompetent to proceed, the circuit court exceeded its authority pursuant to section 552.020.8 and violated Defendant's due process rights. View "State ex rel. Kelly v. Inman" on Justia Law

The Supreme Court affirmed Defendant's conviction of felony possession of a controlled substance, holding that the circuit court did not err in admitting evidence obtained from Defendant's statements and a search of his vehicle after a traffic stop.On appeal, Defendant argued that the circuit court erred in overruling his motion to suppress because the traffic stop was unreasonable and violated the Fourth Amendment. The Supreme Court affirmed, holding (1) crossing the fog line and driving on the shoulder is a traffic violation and creates a lawful justification for a traffic stop; and (2) the stop in this case was justified after Defendant's vehicle crossed the fog line and drove on the shoulder and therefore did not constitute an unreasonable seizure under the Fourth Amendment. View "State v. Smith" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the trial court entering judgment in favor of the cities of Aurora, Cameron, Oak Grove, and Wentzville (collectively, the Cities) in this action for declaratory judgment and injunctive relief against CenturyLink, Inc. and its subsidiaries, holding that the trial court erred in awarding prejudgment interest and attorneys fees to the Cities.In their petition, the Cities alleged that, since 2000, CenturyLink failed to pay all license taxes owed under the Cities' respective ordinances. Further, the Cities alleged that CenturyLink failed to enter into right-of-way user agreements under Cameron's and Wenzville's respective ordinances and failed to pay Cameron's linear foot fees. The trial court entered partial summary judgments in favor of the Cities on the issue of liability. After a trial, the court entered a final judgment for the Cities on the issue of damages. The trial court then awarded the Cities attorney fees, prejudgment interest, and postjudgment interest. The Supreme Court reversed in part and remanded the cause, holding that the trial court (1) erred in awarding prejudgment interest to the Cities, and (2) erred in awarding attorney fees to three of the cities. View "City of Aurora, Missouri v. Spectra Communications Group, LLC" on Justia Law

The Supreme Court affirmed the judgment of the circuit court granting summary judgment in favor of the State and intervenors (collectively, Defendants) on the City of Chesterfield's action seeking a declaration that Mo. Rev. Stat. 66.600 and 66.620 are constitutionally invalid special laws, holding that sections 66.600 and 66.620 are not special laws.On appeal, Chesterfield argued that the trial court erred in failing to find that the statutes were constitutionally invalid special laws because the general assembly changed the population classification of section 66.600 to exclude St. Charles County, and that 66.620 creates a closed class based on immutable, historical, and geographic facts and is not substantially justified. The Supreme Court affirmed, holding that the circuit court did not err in granting summary judgment for Defendants because Defendants articulated a rational basis for the classifications in sections 66.600 and 66.200. View "City of Chesterfield v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's claims for relief under the Missouri Human Rights Act (MHRA) for age discrimination and retaliation, holding that the Court was precluded from applying the MHRA to Appellant's claims.Respondent filed a motion to dismiss Appellant's claim, arguing that his petition did not state a claim upon which relief could be granted because the MHRA does not apply to an Illinois employee who faced alleged discriminatory acts in Illinois. The circuit court dismissed the petition with prejudice. The Supreme Court affirmed, holding that because Appellant was aggrieved solely in Illinois, the express language of the MHRA, coupled with the presumption against extraterritorial application of laws, precluded that Court from applying the MHRA to Appellant's claims. View "Tuttle v. Dobbs Tire & Auto Centers, Inc." on Justia Law

The Supreme Court affirmed the circuit court's judgment holding that the St. Louis City Board of Election Commissioners violated the sunshine law, Mo. Rev. Stat. 610.010 et seq., in refusing to produce absentee ballot applications and envelopes to David Roland, holding that St. Louis absentee ballot applications have ceased being protected from disclosure by law.The circuit court declared that the election board had violated the sunshine law by withholding the absentee ballot applications and ballot envelopes and then taxed costs against Roland in regard to the election board's defense of Roland's assertion that the election board's violation was purposeful or knowing. The Supreme Court reversed in part, holding (1) the circuit court did not err in declaring that the ballot applications were subject to disclosure, and ballot envelopes are open to the public after the voted ballot is removed; and (2) the election board was not entitled to costs under either the sunshine law or the general law governing the award of costs. View "Roland v. St. Louis City Board of Election Commissioners" on Justia Law

The Supreme Court quashed a preliminary writ of prohibition it issued directing the circuit court to vacate a portion of its order overruling Relator's motion to dismiss and to dismiss the underlying plaintiff's petition with prejudice for failure to state a claim upon which relief could be granted, holding that Plaintiff had an adequate remedy by way of appeal.Plaintiff filed a complaint of discrimination alleging violations of the Missouri Human Rights Act (MHRA). The circuit court concluded that Plaintiff stated a claim under the MHRA and denied Relator's motion to dismiss. Relator sought a writ of prohibition directing the circuit court to vacate the portion of its order overruling Relator's motion to dismiss. The Supreme Court issued a preliminary writ of prohibition. At the time, the lower courts did not have the benefit of the Supreme Court's opinion in Tuttle v. Dobbs Tire & Auto Centers, Inc., __ S.W.3d __ (Mo. banc 2019). The Supreme Court then quashed the preliminary writ, holding that the MHRA did not provide Plaintiff with relief and that, as demonstrated by Tuttle, Relator may seek relief by appeal after a final judgment. View "State ex rel. Anheuser-Busch, LLC v. Honorable Joan L. Moriarty" on Justia Law

The Supreme Court reversed the judgment of the circuit court finding in favor of Plaintiffs on their negligent credentialing claim against Defendant, St. Luke's Surgicenter-Lee's Summit LLC, holding that Plaintiffs failed to make a submissible case of negligent credentialing.In their complaint, Plaintiffs alleged that Defendant negligently granted a surgeon operating out of St. Luke's Surgicenter in Lee's Summit staff privileges at its hospital. After a jury trial, the circuit court entered judgment in favor of Plaintiffs. The Supreme Court reversed the judgment of the trial court and remanded the case for a new trial, holding that the circuit court erred in overruling Defendant's motion for judgment notwithstanding the verdict because Plaintiffs failed to make a submissible case of negligent credentialing. View "Tharp v. St. Luke's Surgicenter-Lee's Summit, LLC" on Justia Law

The Supreme Court affirmed the judgment of the motion court denying Defendant's motion for postconviction relief filed under Mo. R. Crim. P. 29.15, holding that the motion court did not err in denying postconviction relief.Defendant was convicted of murder in the first degree, armed criminal action, burglary in the first degree, and unlawful possession of a firearm by a felon. The trial court sentenced Defendant to death. Defendant later moved for postconviction relief, alleging ineffective assistance of counsel. The motion court denied the postconviction motion. The Supreme Court affirmed, holding that the motion court did not err in denying Defendant's claims. View "Hosier v. State" on Justia Law

The Supreme Court affirmed the judgments of the circuit court granting summary judgment for Respondents and dismissing Appellants' five separate actions for fraudulent concealment, holding that Appellants' claims for fraudulent concealment were barred by Mo. Rev. Stat. 516.120(5).In 2010 and 2011, Appellants filed five separate, but similar, wrongful death lawsuits against Respondents. The circuit court dismissed the wrongful death suits. In 2016, Appellants filed five separate, but almost identical, petitions alleging fraudulent concealment by Respondents, alleging that Respondents damaged Appellants by causing them to lose their right to timely file wrongful death causes of action. The circuit court found Appellants claims were barred both by the doctrine of res judicata and by the five-year statute of limitations for fraud claims set forth in Mo. Rev Stat. 516.120(5). The Supreme Court affirmed, holding that Appellants' claims were barred by section 516.120(5). View "Boland v. Saint Luke's Health System" on Justia Law