Justia Missouri Supreme Court Opinion Summaries

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

The Supreme Court reversed the judgment of the trial court awarding Matthew Vacca actual and punitive damages, including substantial future lost wages, on his claim that he was retaliated against for filing a complaint with the Missouri Commission on Human Rights and Equal Employment Opportunity Commission alleging disability discrimination, holding that the trial court abused its discretion in refusing to apply judicial estoppel to Vacca’s claim of future lost wages.The circuit court found Vacca claimed in this case that he could have continued to work as an administrative law judge (ALJ) for twenty more years. In Vacca’s ongoing dissolution proceeding, however, he claimed he was entitled to maintenance because he was totally unable to work due to his disability. The circuit court concluded that it was barred from applying judicial estoppel because the dissolution judgment had been remanded for further proceedings based on evidentiary errors. The Supreme Court reversed, holding (1) once a party takes inconsistent positions, there are no fixed prerequisites to application of judicial estoppel; and (2) the trial court abused its discretion in refusing to apply judicial estoppel to preclude Vacca from making the inconsistent claim that he was able to work as an ALJ for another twenty years with reasonable accommodations. View "Vacca v. Missouri Department of Labor & Industrial Relations, Division of Workers' Compensation" on Justia Law

The Supreme Court quashed its preliminary writ of mandamus to compel the circuit court to dismiss with prejudice Relator’s charge of driving while intoxicated, holding that Relator did not demonstrate a clear and unequivocal right to the dismissal of his charge because the plain language of Mo. Rev. Stat. 577.037.2 does not require a pretrial hearing or pretrial determination on the motion.Relator filed a motion under section 577.037.2 asserting that because the chemical analysis demonstrated that his blood alcohol concentration was under the legal limit, and because the State did not present evidence to prove the dismissal was unwarranted, the charge should be dismissed. The circuit court overruled the motion. Relator then sought a writ of mandamus. The Supreme Court quashed its preliminary writ of mandamus, holding (1) a pretrial hearing or pretrial determination on the section 577.037.2 motion is not required; (2) the circuit court has discretion to order that a hearing and determination on the motion be deferred until trial; and (3) because the circuit court’s overruling of the motion effectively deferred the matter until trial, Relator could seek relief on appeal. View "State ex rel. McCree v. Honorable Wesley Dalton" on Justia Law

The Supreme Court affirmed the suspension of Appellant’s driver’s license for driving while intoxicated, holding that Appellant’s arguments on appeal were unavailing.Specifically, the Court held (1) the filing of a report with the department of health and senior services showing that a driver’s blood alcohol content was over the legal limit is a collateral requirement that does not affect the performance of the test or its validity or accuracy, and therefore, the failure to timely make that filing was not preclude admission of the report; (2) the implied consent notice complied with due process because it accurately informed Appellant that his license would be suspended immediately if he refused the breath test; and (3) a later notice of suspension given Appellant after he failed the breath test accurately informed him of the facts statutorily required to suspend his license and how to request a hearing. View "Carvalho v. Director of Revenue" on Justia Law

The Supreme Court reversed the orders of the circuit court overruling motions to retax court costs after each movant had his jail board bill taxed as costs against him by the circuit court, holding that no statutory authority exists to treat jail board bills as court costs.Both movants were sentenced to a term in jail. The circuit clerks taxed to the movants as court costs a jail board bill. The movants later filed motions to retax costs, arguing that the circuit court had no statutory authority to tax their board bills as court costs. The circuit courts overruled the motions. The Supreme Court reversed the rulings on both motions and remanded with direction for the circuit court to retax the costs by removing the board bill liability of the movants under Mo. Rev. Stat. 221.070 from their respective fee reports, holding that the circuit courts erred in taxing as court costs the movants’ board bills, as express statutory authority permitting jail board bills to be taxed as court costs does not exist. View "State v. Richey" on Justia Law

The Supreme Court made permanent its preliminary writ of prohibition preventing the circuit court from taking any action in this case other than discharging Relator from probation, holding that the circuit court lacked authority over Relator and could not hold a hearing to revoke her probation.During Relator’s term of probation, the division of probation and parole issued notices of citation, but none of those notices resulted in the issuance of probation violation warrants or the suspension of Relator’s probation. After a field violation report was filed, however, the circuit court suspended Relator’s probation. After a probation violation hearing was scheduled, Relator sought a petition for a writ of prohibition. The Supreme Court issued a preliminary writ, which it made permanent, holding (1) the notices of citation were not “initial violation reports” or “violation reports” pursuant to Mo. Rev. Stat. 217.703, and therefore, the division’s issuances of notices of citation did not stop the accrual of earned compliance credits because Relator was not out of compliance with the terms of her probation; and (2) after the optimal discharge date passed, the circuit court did not have the authority to hold a probation revocation hearing and, rather, should have discharged Relator from probation. View "State ex rel. Coleman v. Honorable Horn" on Justia Law

The Supreme Court reversed the judgment of the circuit court against St. Luke’s Surgicenter-Lee’s Summit LLC on a negligent credentialing claim brought by Thomas and Paula Tharp, holding that the Tharps failed to make a submissible case of negligent credentialing.Thomas Tharp suffered injuries when a surgeon operating out of St. Luke’s damaged his hepatic duct and common bile duct. The Tharps filed suit against the surgeon and St. Luke’s and then settled with the surgeon. The Tharps proceeded to trial against St. Luke’s on the claim that St. Luke’s negligently granted the surgeon staff privileges at its hospital. The jury returned a verdict in favor of the Tharps, and the circuit court entered judgment in favor of the Tharps. The Supreme Court reversed, holding that there was insufficient evidence to support the Tharps’s negligent credentialing claim. View "Tharp v. St. Luke's Surgicenter-Lee's Summit, LLC" on Justia Law