Justia Missouri Supreme Court Opinion Summaries

Ashley Colville was charged with second-degree involuntary manslaughter following a motor vehicle accident in St. Louis, Missouri, in which Rodney Larue was fatally injured. The indictment alleged that Colville caused Larue's death by colliding with his vehicle and did so with criminal negligence by failing to yield and use a turn signal. Colville filed a motion to dismiss the indictment, arguing it was insufficient because it failed to state the offense charged.The Circuit Court of St. Louis dismissed the indictment with prejudice. The court held that Colville's alleged failure to yield and signal did not amount to criminal negligence, an essential element of second-degree involuntary manslaughter. The court based its decision on a review of several exhibits, including a video surveillance recording of the accident, and concluded that Colville's actions did not constitute a "gross deviation" that could legally be found criminally negligent.The Supreme Court of Missouri vacated the lower court's judgment and remanded the case for further proceedings. The Supreme Court held that the lower court erred in dismissing the indictment because it was sufficient in all required respects. The court clarified that at the motion to dismiss stage, the court's review of an indictment is limited to determining whether the indictment contains the essential elements of the offense and whether it apprises the defendant of facts constituting the charge. The court found that the indictment against Colville met these requirements. The court also noted that whether the state has satisfied its burden in proving Colville committed the offense charged is not capable of determination without a trial. View "State of Missouri vs. Colville" on Justia Law

In September 2016, Sanford Sachtleben and Luciann Hruza (the Buyers) purchased a property in Missouri from Perry and Joanie Sullivan (the Sellers). Prior to the sale, the city of New Melle had sued the Sellers over a barn they had built on the property, alleging it violated city zoning ordinances. The Buyers were added as defendants to this lawsuit after they purchased the property. The Buyers demanded coverage from their title insurance company, Alliant National Title Insurance Co. (Alliant), but Alliant refused. The Buyers then sued Alliant, claiming it had breached the title insurance policy by refusing to defend them in the New Melle lawsuit.The case was first heard in the Circuit Court of St. Louis County, where Alliant moved for summary judgment. The circuit court granted Alliant's motion, concluding that the unambiguous language of the title insurance policy provided no coverage for the Buyers. The Buyers appealed this decision.The Supreme Court of Missouri affirmed the lower court's decision. The court found that the title insurance policy was unambiguous and did not provide coverage for the Buyers. The court noted that the policy provided coverage only if a notice, describing any part of the land, was recorded in the public records setting forth the violation or intention to enforce. Since no such notice was recorded, the court concluded that the policy did not provide coverage. The court also rejected the Buyers' arguments that other provisions of the policy provided coverage, finding that these arguments were precluded by an exclusion in the policy. View "Sachtleben vs. Alliant National Title Insurance Co." on Justia Law

The case involves Lorandis Phillips, who was convicted of first-degree robbery and second-degree assault. The incident occurred on December 14, 2018, when Phillips and three other men attacked a man in a shed behind Phillips' house. The victim was struck in the head, causing him to fall and lose consciousness briefly. The men then stole his cell phone, wallet, and car keys. Phillips was arrested and charged with the crimes.Phillips appealed his conviction, raising seven points. He argued that he was not represented by counsel at an appearance prior to his preliminary hearing, that the court failed to preserve a recording or transcript of that appearance, that the court erred in allowing his felony information to be amended, that there was insufficient evidence to support a conviction on the robbery count, and that there was a deficiency in the amended information for the assault count.The Supreme Court of Missouri affirmed the lower court's decision. The court found that Phillips' lack of counsel at his initial appearance did not constitute plain error, as he had not shown that he was prejudiced by the absence of counsel. The court also found that the lower court did not err in allowing the felony information to be amended, as the amendment did not prejudice Phillips' substantial rights. The court further found that there was sufficient evidence to support the robbery conviction, and that any deficiency in the amended information for the assault count did not prejudice Phillips. View "State v. Phillips" on Justia Law

The case revolves around James Logan, who was convicted of three misdemeanor offenses: first-degree trespass, fourth-degree assault, and peace disturbance. These offenses occurred at a Mexican restaurant in Columbia, where Logan was seen yelling at customers and causing a disturbance. Despite being previously warned by the restaurant owner and the police, Logan continued his disruptive behavior, leading to a physical altercation with the owner. Logan was later arrested and charged with the aforementioned misdemeanors.Logan was initially denied bond due to his perceived danger to the community. However, he was later released on his own recognizance, subject to conditions including completion of a substance use treatment program and refraining from committing new offenses. Logan violated these conditions by committing additional offenses and failing to complete the treatment program. His release was subsequently revoked.The Circuit Court of Boone County found Logan guilty of all charges and sentenced him to jail time and probation, which included participation in a mental health treatment program. Logan appealed his convictions, arguing that his right to counsel was violated and that the evidence was insufficient to support his convictions.The Supreme Court of Missouri, however, chose to apply the escape rule, which denies the right of appeal to a defendant who evades justice. The court found that Logan's repeated failure to appear for his probation revocation hearing and his commission of additional criminal offenses during this period adversely affected the criminal justice system. Therefore, the court dismissed Logan's appeal. View "State of Missouri vs. Logan" on Justia Law

The case involves Tiffany Mills, who was convicted for third-degree assault and armed criminal action. Mills had a confrontation with a woman (the victim) who was friends with her boyfriend. The confrontation escalated into a physical fight, during which Mills stabbed the victim seven times. Mills claimed self-defense, stating that the victim attacked her first. The victim suffered severe injuries, including a lacerated spleen, a partially collapsed lung, and significant blood loss.The case was initially heard in the Circuit Court of Jackson County, where Mills was found guilty of third-degree assault and armed criminal action. Mills appealed her conviction, arguing that the circuit court erred in failing to hold a jury-tried punishment stage, excluding certain evidence during the trial, and failing to appoint counsel at her initial appearance before the court.The Supreme Court of Missouri reviewed the case and found no error in the lower court's judgment. The court held that Mills had validly waived her right to jury sentencing when she requested the judge to determine her punishment. The court also found that the circuit court did not abuse its discretion in excluding evidence of specific instances of the victim's violent behavior. Lastly, the court held that a proceeding during which the circuit court considers or determines conditions for pretrial release is not a critical stage requiring the presence of counsel. Therefore, the court affirmed the circuit court's judgment. View "State of Missouri, Respondent, vs. Tiffany Mills, Appellant." on Justia Law

In this case, Quinton Lucas, a registered voter, challenged the approval of Amendment No. 4 in the November 2022 general election. The amendment authorized laws that increased minimum funding for a police force established by a state board of police commissioners. Lucas claimed that the fiscal note summary printed on every ballot cast in the election materially misstated the fiscal note for the measure.The Supreme Court of Missouri, which was reviewing the case, had previously overruled the state's motion to dismiss Lucas' claim. The state had argued that Lucas' contest was time-barred, that the city lacked standing as a voter, and that the statutes providing remedies if an election contest succeeds were unconstitutional.The Supreme Court of Missouri found that the fiscal note summary was both materially inaccurate and seriously misleading. The court held that this constituted an "irregularity" of sufficient magnitude to cast doubt on the validity of the election. As a result, the court ordered a new election on the question to be conducted as part of the statewide general election on November 5, 2024. View "Lucas vs. Ashcroft" on Justia Law

In 2019, MO CANN Do, Inc. (MCD) applied for a medical marijuana cultivation license in Missouri. However, the Department of Health and Senior Services (DHSS) rejected MCD's application as it failed to include a certificate of good standing demonstrating its authorization to operate as a business in Missouri. An administrative hearing commission upheld DHSS's decision, and MCD appealed to the circuit court, which also affirmed the decision.The Supreme Court of Missouri found that MCD's application did not meet the minimum standards for licensure, as it failed to provide a certificate of good standing from the Secretary of State, as required by DHSS's regulations. MCD argued that its certificate of incorporation satisfied the standard requiring proof of authorization to operate as a business in Missouri, but the Court disagreed, stating that the regulatory language was unambiguous and the certificate of good standing was a specific requirement.MCD further argued that DHSS waived the certificate of good standing requirement by failing to specify it in the deficiency letter sent to MCD. The Court rejected this argument, stating that DHSS never affirmatively waived the deficiencies in MCD's application.Lastly, MCD claimed that DHSS should be estopped from denying its application based on the missing certificate of good standing due to its failure to notify MCD of this specific deficiency. The Court denied this claim, stating that it is generally inappropriate to estop governmental agencies tasked with administrating licensure in highly regulated industries, which include the marijuana industry. In conclusion, the Supreme Court of Missouri affirmed the circuit court’s judgment. View "MO CANN Do, Inc. vs. Missouri Department of Health and Senior Services" on Justia Law

On December 13, 2023, the Supreme Court of Missouri issued an execution warrant for Brian Dorsey, who is serving a death sentence for two counts of first-degree murder. Subsequently, Dorsey filed two petitions for writ of habeas corpus, arguing that he is innocent as he was incapable of deliberation due to drug-induced psychosis at the time of the offenses, that his trial counsel was ineffective due to a conflict of interest resulting from a flat-fee arrangement, and that his execution would violate the Eighth Amendment as he belongs to a unique class of persons for whom the penological goals supporting capital punishment are no longer met.The Court found that Dorsey failed to present any legally cognizable claims for habeas relief. He did not deny committing the murders and failed to establish that he was actually innocent of first-degree murder. The Court had previously found Dorsey's claim of ineffective assistance of counsel due to a conflict of interest to be without merit, and he was procedurally barred from raising this claim again. Lastly, Dorsey's Eighth Amendment claim was deemed without merit and was interpreted as a plea for clemency, which is beyond the Court's review and authority. Therefore, both petitions for writ of habeas corpus were denied. View "State ex rel. Dorsey vs. Vandergriff" on Justia Law

The plaintiff, Yarnell, filed a wrongful death action against Clinton No. 1, Inc., a healthcare and rehabilitation center, alleging that Clinton's negligence led to her mother's death from COVID-19. The Missouri Supreme Court addressed whether Clinton's proposed theories of immunity barred Yarnell's claims, which were based on the Public Readiness and Emergency Preparedness (PREP) Act and two Missouri acts.Yarnell's mother had contracted with Clinton for a private room, but Clinton placed her with a roommate, which Yarnell claimed exposed her mother to COVID-19, violated their agreement, and ultimately led to her mother's death. Clinton argued that Yarnell's claims were barred by the PREP Act, which provides immunity for healthcare providers administering or using covered countermeasures during a public health emergency, and Missouri laws granting immunity to healthcare providers during an emergency declared by the governor and in COVID-19 exposure actions.The court found that Yarnell's petition did not implicate a covered countermeasure under the PREP Act, as it made no reference to the administration or use of a diagnostic test or any other covered countermeasure. The court also found that Clinton failed to demonstrate it agreed to be deployed during the emergency or that the governor or any state agency acted on such agreement and deployed Clinton, which would have entitled it to immunity under Missouri law. Lastly, the court noted that Yarnell had adequately alleged her harm was caused by Clinton's recklessness, and the two COVID-19 statutes would not foreclose relief if Yarnell were able to prove such recklessness. Therefore, the court quashed its preliminary writ of mandamus, allowing Yarnell's case to proceed. View "State ex rel. Clinton No. 1 vs. Baker" on Justia Law

Seven individuals sought a writ of mandamus or prohibition from the Supreme Court of Missouri, claiming the circuit court failed to hold a preliminary hearing within the required timeframe, thus violating Rule 22.09(a), section 544.270, and section 544.320. The plaintiffs argued that this delay was to allow the circuit attorney additional time to secure an indictment. The primary plaintiff, Lamar Lamont Woods, had been held without bond for 162 days on the complaint, with his preliminary hearing delayed for 129 days beyond the 30-day deadline in Rule 22.09(a).The Supreme Court of Missouri noted that after the filing of a felony complaint, a preliminary hearing should be held within a reasonable time, but no later than 30 days following the defendant's initial appearance if the defendant is in custody, and no later than 60 days if the defendant is not in custody. The Court concluded that Woods was not entitled to a preliminary hearing on his charges, as he had been indicted on the same charges at issue in the complaint filed in June 2023. Since Woods had been indicted, the Court ruled that any relief it might issue in mandamus would not have practical effect on any existing controversy, thus rendering the case moot.The Court also concluded that the "capable of repetition, yet evading review" exception to the mootness doctrine did not apply in this case, as Woods had not established this issue would recur. Consequently, the preliminary writ of mandamus was quashed. View "State ex rel. Woods vs. Dierker" on Justia Law