Justia Missouri Supreme Court Opinion Summaries

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The Supreme Court vacated the judgment of the circuit court convicting Defendant of fifteen counts of unlawful possession of a firearm following a jury trial, holding that the circuit court committed reversible error by allowing the jury to hear a prejudicial, out-of-court statement made by a witness who never appeared or testified at trial.After Defendant was arrested on allegations of domestic violence against his wife, Beckey, Beckey told officers that Defendant illegally possessed numerous firearms. Defendant was subsequently charged with fifteen counts of unlawfully possessing a firearm. During trial, the out-of-court statement made by Beckey, who did not appear at trial, was elicited during an officer's testimony. The circuit court ruled that Beckey’s statement could be considered as substantive evidence. Defendant was subsequently convicted. The Supreme Court vacated the conviction, holding that the circuit court prejudicially erred in allowing the officer's testimony over Defendant's violation. View "State v. Hollowell" on Justia Law

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The Supreme Court affirmed the order of the circuit court confirming an arbitration award in favor of Car Credit, Inc., holding that the arbitration agreement was valid and that the circuit court did not err.Cathy Pitts entered into a retail installment contract and security agreement with Car Credit to purchase and finance a vehicle. The parties also entered into a written arbitration agreement. After Car Credit repossessed the vehicle and sued Pitts for the remaining deficiency balance Pitts filed a counterclaim alleging an unlawful and deceptive pattern of wrongdoing followed by Car Credit. The circuit court sustained Car Credit's motion to compel arbitration. The arbitrator entered an award on the merits' of Pitts' claim in favor of Car Credit. The circuit court entered judgment for Car Credit on all causes of action in accordance with the arbitration award. The Supreme Court affirmed, holding that the arbitration agreement was enforceable. View "Car Credit, Inc. v. Pitts" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court reducing the jury's punitive damages award against HALO Branded Solutions, Inc., holding that the circuit court's application of the punitive damages cap in Mo. Rev. Stat. 510.265 did not violate All Star Awards & Ad Specialities Inc.'s right to a jury trial, and the reduced award did not violate HALO's due process rights.All Star brought this action against HALO and All Star's employee, Doug Ford. A jury found HALO tortiously interfered with All Star's business expectancy, that Ford breached his duty of loyalty to All Star, and that HALO conspired with Ford to breach this duty of loyalty. The jury awarded All Star $525,542 in actual damages and assessed $5.5 million in punitive damages against HALO. The circuit court applied section 510.265 and capped the punitive damages award at five times All Star's actual damages - or $2,627,709 - and entered final judgment in accordance with the jury's verdicts. The Supreme Court affirmed, holding (1) the circuit court properly reduced All Star's award of punitive damages; and (2) the reduced award was within the constitutional parameters of due process. View "All Star Awards & Ad Specialties, Inc. v. HALO Branded Solutions, Inc." on Justia Law

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The Supreme Court reversed the judgment of the circuit court finding Defendant to be a dangerous offender and remanded the case for resentencing, holding that the State failed to plead all essential facts and introduce evidence establishing sufficient facts to warrant a finding beyond a reasonable doubt that Defendant was a dangerous offender.A jury found Defendant guilty of four counts of second-degree burglary and sentenced him to a total of thirty years' imprisonment. On appeal, Defendant argued that the circuit court committed plain error in finding that he was a dangerous offender. The Supreme Court agreed and reversed Defendant's sentences, holding that the circuit court plainly erred in sentencing Defendant to sentences greater than the maximum authorized by law, resulting in manifest injustice. View "State v. Yount" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the circuit court determining that Mo. Rev. Stat. 595.201, as applied to defense attorneys, is constitutionally invalid and that the passage of Senate Bill 569 (SB 569) was procedurally proper, holding that the circuit court did not err in its judgment.Plaintiffs - five public defenders and three criminal defendants - brought this action for declaratory and injunctive relief challenging the constitutional validity of statutes relating to victims of sexual offenses, including SB 569 and section 595.021, which requires criminal defense attorneys to provide information to victims of sexual assault offenses. The circuit court (1) declared section 595.201 constitutionally invalid as as applied to defense counsel because it violated defense attorneys' rights to freedom of speech, and (2) rejected procedural challenges to SB 569 as a whole. The Supreme Court affirmed, holding that the circuit court properly determined that (1) section 595.201.2(4)'s requirements violate defense attorneys' free speech rights, and (2) the General Assembly complied with the procedural limitations imposed by the Missouri Constitution in passing SB 569. View "Fox v. State" on Justia Law

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The Supreme Court reversed the decision of the circuit court sustaining Defendant's motion to dismiss one count of possession of a controlled substance, holding that the circuit court's decision to dismiss the possession count on double jeopardy grounds was erroneous.Defendant was charged with five counts, including the possession count and one count of unlawful use of a weapon by possessing a firearm while in possession of a controlled substance (UUW-possession), all stemming from the same incident. Defendant plead guilty to all counts except the possession count, arguing that because he had been convicted of the greater offense of UUW-possession via his guilty plea, any subsequent prosecution for possession would constitute a double jeopardy violation. The circuit court dismissed the possession count. The Supreme Court reversed, holding that the circuit court erred by dismissing the possession count against Defendant. View "State v. Andrews" on Justia Law

Posted in: Criminal Law
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The Supreme Court dismissed this appeal from the decision of the Labor and Industrial Relations Commission (Commission) reversing the administrative law judge's award and denying Claimant permanent total disability benefits, holding that Claimant's brief preserved nothing for appellate review because it failed to comply with the mandatory and straightforward rules governing the contents of an appellant's briefs.After the Commission denied Claimant's claim, Claimant appealed. The Supreme Court dismissed the appeal, holding that each of Claimant's points on appeal was defective because each point relied on wholly failed to follow the simple template provided in Rule 84.04. View "Lexow v. Boeing Co." on Justia Law

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The Supreme Court granted a preliminary writ of prohibition to Kimberly Barks preventing the disclosure of her medical records, holding that Barks did not waive the physician-patient privilege by pleading the affirmative defenses of comparative fault and assumption of risk.A golf cart driven by Barks and ridden in by Sheila Spencer was involved in an accident. Spencer sued Barks, alleging negligence. Barks denied the allegations and, alternatively, asserted several affirmative defenses, including comparative fault and implied primary assumption of risk. Spencer sought discover of Barks' medical records from the night of the accident, which Barks objected to. The circuit court subsequently sustained Spencer's motion to compel discovery of Barks' medical records. Barks then filed a petition for writ of prohibition or mandamus. The Supreme Court granted the writ, holding that Barks's affirmative defense did not constitute a waiver of the physician-patient privilege. View "State ex rel. Barks v. Honorable Pelikan" on Justia Law

Posted in: Personal Injury
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The Supreme Court vacated the order of the circuit court entering a declaratory judgment that Mo. Rev. Stat. 115.646 violated public officials' right to free speech and was void for vagueness, holding that the circuit court erred.Section 115.646 prohibits officials from directly using public funds to advocate, support, or oppose a ballot measure or candidate for public office. Plaintiffs initiated a lawsuit seeking a judgment declaring section 115.646 unconstitutional. The circuit court sustained Plaintiffs' motion for summary judgment, declaring that section 115.646 violated the officials' First Amendment rights. The Supreme Court vacated the judgment, holding (1) because section 115.646 regulates the use of public funds, not the officials' speech, it does not implicate the free speech clause of the First Amendment; and (2) the circuit court erred in declaring certain words and phrases in the statute to be unconstitutionally vague. View "City of Maryland Heights v. State" on Justia Law

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The Supreme Court affirmed the order of the circuit court issuing a declaratory judgment invalidating Mo. Rev. Stat. 116.180 and 116.334.2, which prohibit the collection of referendum petition signatures before the Secretary of State has certified the referendum's official ballot title and affixed it to the petition, holding that there was no error.In invalidating sections 116.180 and 116.334.2, the circuit court declared that those provisions interfere with and impede the right of referendum, therefore conflicting with Mo. Const. art. III, 49 and 52(a). The Supreme Court affirmed the judgment declaring those statutes constitutionally invalid, holding that the statutes' prohibition on collecting referendum petition signatures before the Secretary certifies the official ballot title unreasonably shores the timeframe for petition circulation, thus interfering with and impeding the constitutional right of referendum reserved to the people. View "No Bans on Choice v. Ashcroft" on Justia Law