Justia Missouri Supreme Court Opinion Summaries

The Supreme Court made permanent its preliminary writ of prohibition prohibiting the circuit court from holding a probation revocation hearing and ordered the circuit court to discharge Travis Jones from probation, holding that Jones's term of probation had expired, and therefore, the circuit court lost the power to revoke his probation.As grounds for the writ, Jones argued that the circuit court failed to make every reasonable effort to hold his probation revocation hearing prior to the expiration of his term of probation and lost authority to do anything other than order his discharge from probation. The Supreme Court agreed, holding that the Court lost the power to revoke Jones's probation because it failed to make every reasonable effort to bring Jones before the court before the term of probation expired. View "State ex rel. Jones v. Honorable Eric Eighmy" on Justia Law

The Supreme Court made permanent a preliminary writ of mandamus requiring Respondent to transfer the underlying declaratory judgment action from Greene County to Pulaski County, holding that Greene County was an improper venue because none of the defendants in the underlying action resided in Greene County.An automobile accident that killed Juanita Prater occurred in Pulaski County. Relators filed a wrongful death action against the driver of the other car, Dakota Ball, in Pulaski County. Ronald Prater filed a personal injury action against Ball in Pulaski County. The parties later agreed to transfer the wrongful death and personal injury action to Greene County. USAA General Indemnity Company filed a declaratory judgment action in Greene County seeking a declaration that the auto policy it issued to Ball's stepmother did not cover Ball. None of the defendants resided in Greene County. After unsuccessfully filing a motion to transfer venue, Relators filed a petition for a writ of mandamus or prohibition. The Supreme Court granted a writ of mandamus, holding that the circuit court failed to execute its ministerial duty to transfer the declaratory judgment action from Greene County to a proper venue. View "State ex rel. Prater v. Honorable Jason R. Brown" on Justia Law

The Supreme Court made permanent a writ of prohibition to prevent the circuit court from ordering Relator to submit to a mental evaluation pursuant to Mo. Rev. Stat. chapter 552, holding that chapter 552 did not authorize the circuit court to order the department of mental health to conduct a psychiatric evaluation of Relator.Relator was charged with first-degree murder, second-degree burglary, and other offenses. Relator asserted that he was not guilty by reason of mental disease or defect. The State sought an order for a mental evaluation pursuant to chapter 552. The circuit court granted the motion. Relator then petitioned the court of appeals for a writ of prohibition, and the court of appeals granted the writ. The Supreme Court granted transfer and made permanent a writ of probation, holding that the circuit court exceeded its authority by ordering Relator to undergo a mental evaluation pursuant to chapter 552 when Relator intended to rely only on the diminished capacity defense because the circuit court lacked reasonable cause to question his competence to stand trial. View "Caruthers v. Honorable Wendy Wexler-Horn" on Justia Law

The Supreme Court affirmed the judgment of the motion court overruling Appellant's Mo. R. Crim. P. 29.15 motion for post-conviction relief alleging several claims of ineffective assistance of trial and appellate counsel, holding that Appellant's claims of error were unavailing.After a jury trial, Appellant was found guilty of one count of first-degree murder for the death of a Missouri highway patrolman. The jury was unable to agree whether to recommend a sentence of death or life imprisonment. The circuit court subsequently conducted an independent review of the facts and imposed a death sentence. The Supreme Court affirmed on appeal. Thereafter, Appellant filed his Rule 29.15 motion. The motion court denied the motion after an evidentiary hearing. The Supreme Court affirmed, holding, among other things, that counsel were not ineffective in failing to question Juror 58 during voir dire about the provocative and violent novel he admitted writing and in failing to call other jurors in support of Appellant's motion for new trial. View "Shockley v. State" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the circuit court dismissing a petition seeking a declaratory judgment that Governor Michael Parson's appointment of Mike Kehoe to the office of Lieutenant Governor was unauthorized under Mo. Rev. Stat. 105.030, holding that Darrell Cope had standing and that the Governor has the authority to appoint a Lieutenant Governor in the event of a vacancy.The Governor Eric Greitens resigned and Governor Parson succeeded Greitens to the office of Governor, the office of Lieutenant Governor was left vacant. Governor Parson appointed Kehoe to be the Lieutenant Governor. Darrell Cope and the Missouri Democratic Party (MDP) filed a petition seeking injunctive and declaratory relief alleging that Governor Parson lacked legal authority to appoint a Lieutenant Governor. The circuit court dismissed the petition, concluding that Cope and the MDO did not have standing to challenging Governor Parson's appointment of Kehoe. The Supreme Court reversed in part, holding (1) Cope had taxpayer standing to seek a declaratory judgment in this case; and (2) Mo. Const. Art. IV, 4 controls the authority of the Governor to appoint a Lieutenant Governor, and Governor Parson was within his constitutional authority when he appointed Kehoe to the office of Lieutenant Governor. View "Cope v. Parson" on Justia Law

The Supreme Court affirmed the judgment of the circuit court declaring House Bill No. 2007 (HB2007), an appropriations statute, to be unconstitutional and enjoining the State from terminating Plaintiff's employment on the basis of the severed language, holding that restricting funding for the payment of an administrative law judge's (ALJ) salary based on that ALJ's date of appointment violates the separation of powers requirement of the Missouri Constitution.The circuit court declared certain provisions of HB2007 unconstitutional as applied to Plaintiff, an ALJ, severed the unconstitutional language from the statute, and permanently enjoined the State from terminating Plaintiff's employment pursuant to the unconstitutional language. The Supreme Court affirmed, holding that HB2007 is unconstitutional to the extent that it restricts the use of funds for the payment of ALJ salaries based on the ALJ's date of appointment, as applied to Plaintiff, and therefore, Plaintiff was entitled to declaratory relief and the permanent injunction he sought in this case. View "Rebman v. Parson" on Justia Law

The Supreme Court remanded this case resulting in Defendant's convictions of first- and second-degree murder and sentence of death for the first-degree murder and life imprisonment for the second-degree murder, holding that Defendant's second-degree murder conviction must be reversed and that the judgment on the first-degree murder must be reversed as to the penalty phase of the trial.Specifically, the Court held (1) the circuit court erred when it refused to submit Defendant's proposed jury instructions for second-degree murder and voluntary manslaughter in that there was sufficient evidence from which the jury could find that Defendant acted out of sudden passion arising from adequate cause; (2) the circuit court erred in admitting statements made in violation of Defendant's Miranda rights, but the error was harmless; (3) the circuit court violated Defendant's right to due process by admitting evidence of his post-Miranda silence, but those violations were harmless; and (4) the circuit court erred when it overruled Defendant's objection to the State's penalty phase closing argument in which the State made an impermissible reference to Defendant's decision not to testify, and this error required the judgment on the first-degree murder to be reversed as to the penalty phase of the trial. View "State v. Rice" on Justia Law

The Supreme Court made permanent a preliminary writ of prohibition barring the circuit court from taking any further action other than vacating its order granting class certification, holding that the circuit court abused its discretion by certifying an overly broad class with a class representative whose claims were not typical of the class.Plaintiff filed the underlying class action on behalf of all other similarly situated Missouri consumers alleging that Defendant and its predecessors or successors violated statutory notice requirements relating to the repossession and disposition of collateral and collected unlawful interest following default and repossession of the collateral. The circuit court certified two classes and designated Plaintiff as the sole class representative. Defendant then filed a petition for a writ of prohibition arguing that the circuit court abused its discretion by certifying the class. The Supreme Court granted the writ, holding that the circuit court abused its discretion by certifying a class with Plaintiff as the sole class representative where her claims were not typical of the class and she was not a member of the subclass. View "State ex rel. General Credit Acceptance Co. v. Honorable David L. Vincent III" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of possession of a controlled substance - methamphetamine - holding that while the State clearly violated the rules of discovery by failing timely to disclose a recorded statement Defendant made, the discovery violation did not warrant the sanction of excluding the evidence.Here, the State did not disclose the recorded statement at issue until four days before trial. Defendant filed a pretrial motion to exclude the recorded statement from evidence as a sanction for the alleged discovery violation. Defendant did not seek a continuance as a remedy to the discovery violation in her pretrial motion. The circuit court overruled Defendant's motion to exclude the evidence. The jury returned a verdict finding Defendant guilty of felony possession of methamphetamine. The Supreme Court affirmed, holding that because a continuance would have remedied any alleged prejudice to Defendant the circuit court did not abuse its discretion in overruling Defendant's motion for sanctions. View "State v. Zuroweste" on Justia Law

The Supreme Court vacated the judgment of the circuit court, after a bench trial, finding Defendant “not guilty” of felony sexual misconduct involving a child by indecent exposure because the statute under which he was charged was unconstitutionally overbroad as applied to Defendant’s case, holding that, based on the record, the Court was unable to ascertain the precise nature of the circuit court’s ruling.On appeal, the State argued that the circuit court’s judgment was equivalent to a dismissal of the indictment following a guilty verdict, and therefore, Defendant was not acquitted of the offense. In response, Defendant argued that the circuit court’s judgment was a judgment of acquittal because the circuit court expressly found him not guilty. Therefore, Defendant argued, the appeal was barred by double jeopardy. The Supreme Court vacated the judgment and remanded the case with instructions to enter a new judgment, holding that the Court could not consider the appeal or motion to dismiss on the merits because the Court was unable to determine if the judgment was an acquittal or a dismissal. View "State v. Ward" on Justia Law