Justia Missouri Supreme Court Opinion Summaries

The circuit court erroneously declared the law when it concluded that an employee’s violation of employer’s rules regarding vehicle operation were sufficient to preclude coverage under the omnibus clause of the employer’s insurance policy.James Campbell, an employee of BNSF Railway Company, rear-ended Ricky Lee Griffitts while driving a BNSF company vehicle. Campbell was intoxicated at the time of the collision. Numerous lawsuits ensued. This appeal was from an equitable garnishment action that Griffitts filed against BNSF and its insurer, Old Republic (collectively, Respondents), to collect on an unsatisfied judgment entered against Campbell in an earlier action. In this action, Griffitts claimed that Campbell was a permissive user under the omnibus clause of the insurance policy Old Republic issued to BNSF. The circuit court concluded that Campbell did not have permission to use the company vehicle at the time of the accident due to his violation of BNSF’s policy on the use of alcohol and drugs, and therefore, Campbell was not a permissive user under the omnibus clause. The Supreme Court reversed, holding that Campbell had permission to use the company vehicle at the time of the accident and that it did not matter, for purposes of insurance coverage, that Campbell was drunk. View "Griffitts v. Old Republic Insurance Co." on Justia Law

The Supreme Court affirmed the judgment of the circuit court quashing its preliminary order in mandamus against the Missouri Democratic Party and its chair and the secretary of state (collectively, Respondents), holding that, under the facts and circumstances of this case, Representative Courtney Curtis failed to show he was entitled to mandamus relief under Mo. Rev. Stat. 115.357.Curtis requested the circuit court issue a writ of mandamus ordering Respondents to accept his declaration of candidacy for the fourteenth senate district pursuant and filing fee as timely filed. The circuit court issued a preliminary order in mandamus then, following a hearing, quashed the preliminary order in mandamus. The Supreme Court affirmed, holding (1) Curtis failed to prove that either the Missouri Democratic Party or its chair were public officials against whom the remedy of mandamus is properly imposed; and (2) because the record did not reflect that Curtis submitted or attempted to submit his filing fee to the secretary of state’s office, the secretary of state did not fail to perform the ministerial duty of accepting Curtis’ filing fee in this case. View "Curtis v. Missouri Democratic Party" on Justia Law

The Supreme Court affirmed the judgment of the circuit court overruling Defendant’s motions to suppress evidence and sentencing Defendant to eight years’ imprisonment in connection with his conviction for possession of a controlled substance.Specifically, the Supreme Court held (1) the circuit court did not err in overruling Defendant’s motions to suppress methamphetamine because Defendant was not unlawfully seized when an officer requested that Defendant produce his driver’s license to verify whether he was driving on a suspended license and Defendant complied with that request; and (2) even though the range of punishment was misstated at the sentencing hearing, Defendant failed to establish that the circuit court imposed sentence based on a mistaken belief. View "State v. Perry" on Justia Law

The Supreme Court affirmed the judgment of the circuit court overruling Defendant’s motions to suppress evidence and sentencing Defendant to eight years’ imprisonment in connection with his conviction for possession of a controlled substance.Specifically, the Supreme Court held (1) the circuit court did not err in overruling Defendant’s motions to suppress methamphetamine because Defendant was not unlawfully seized when an officer requested that Defendant produce his driver’s license to verify whether he was driving on a suspended license and Defendant complied with that request; and (2) even though the range of punishment was misstated at the sentencing hearing, Defendant failed to establish that the circuit court imposed sentence based on a mistaken belief. View "State v. Perry" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of one count of possession of child pornography and sentencing him to fifteen years’ imprisonment.On appeal, Defendant argued (1) the circuit court erred in overruling his motion to suppress evidence because the State failed to prove by a preponderance of the evidence that his consent to the search of his home was voluntary or that exigent circumstances existed warranting officers’ warrantless entry into his home; and (2) he was sentenced based on the circuit court’s “materially false understanding of the possible range of punishment.” The Supreme Court held (1) assuming, without deciding, that Defendant’s consent to the search was not freely and voluntarily given, application of the exclusionary rule was not appropriate because the officers had no knowledge that the search was unconstitutional; and (2) the record did not support a conclusion that the circuit court imposed sentence based on a mistaken belief. View "State v. Pierce" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of one count of possession of child pornography and sentencing him to fifteen years’ imprisonment.On appeal, Defendant argued (1) the circuit court erred in overruling his motion to suppress evidence because the State failed to prove by a preponderance of the evidence that his consent to the search of his home was voluntary or that exigent circumstances existed warranting officers’ warrantless entry into his home; and (2) he was sentenced based on the circuit court’s “materially false understanding of the possible range of punishment.” The Supreme Court held (1) assuming, without deciding, that Defendant’s consent to the search was not freely and voluntarily given, application of the exclusionary rule was not appropriate because the officers had no knowledge that the search was unconstitutional; and (2) the record did not support a conclusion that the circuit court imposed sentence based on a mistaken belief. View "State v. Pierce" on Justia Law

The Supreme Court affirmed the judgment of the motion court overruling, without a hearing, Defendant’s Mo. R. Crim. P. 24.035 motion for postconviction relief from his conviction for assault in the first degree and thirteen-year sentence.In denying Defendant’s motion, the motion court found (1) the record conclusively refuted Defendant’s claims that his guilty plea was not knowingly, voluntarily, and intelligently entered, and (2) the record refuted Defendant’s claim that plea counsel was ineffective for failing to advise Defendant of the defense of acting under sudden passion arising out of adequate cause. The Supreme Court affirmed, holding that the record conclusively refused Defendant’s claims that his plea was not knowing and voluntary and that his plea counsel was ineffective. View "Booker v. State" on Justia Law

The Supreme Court affirmed the judgment of the motion court overruling, without a hearing, Defendant’s Mo. R. Crim. P. 24.035 motion for postconviction relief from his conviction for assault in the first degree and thirteen-year sentence.In denying Defendant’s motion, the motion court found (1) the record conclusively refuted Defendant’s claims that his guilty plea was not knowingly, voluntarily, and intelligently entered, and (2) the record refuted Defendant’s claim that plea counsel was ineffective for failing to advise Defendant of the defense of acting under sudden passion arising out of adequate cause. The Supreme Court affirmed, holding that the record conclusively refused Defendant’s claims that his plea was not knowing and voluntary and that his plea counsel was ineffective. View "Booker v. State" on Justia Law

The Supreme Court affirmed the circuit court’s judgment granting summary judgment in favor of the Missouri Department of Public Safety’s Division of Alcohol and Tobacco Control and dismissing Appellant’s first amended petition for review under Mo. Rev. Stat. 536 on the grounds that Appellant failed to exhaust his administrative remedies.Appellant’s employment with the Division of Alcohol and Tobacco Control was terminated following a disciplinary action. Appellant filed a complaint with the Administrative Hearing Commission. The Commission dismissed the complaint, finding that Appellant was not a merit employee entitled to a hearing before the Commission and that the Division had internal appeal procedures for its employees. Thereafter, Appellant filed an amended petition for review. The circuit court dismissed the petition with prejudice because Appellant failed to exhaust his administrative remedies. The Supreme Court affirmed, holding that the circuit court properly dismissed Appellant’s action because it lacked authority to review the Division’s administrative decision as a “contested case” pursuant to Mo. Rev. Stat. 536.100, as alleged in the first amended petition. View "Nowden v. Division of Alcohol & Tobacco Control, Missouri Department of Public Safety" on Justia Law

The Supreme Court affirmed the circuit court’s judgment granting summary judgment in favor of the Missouri Department of Public Safety’s Division of Alcohol and Tobacco Control and dismissing Appellant’s first amended petition for review under Mo. Rev. Stat. 536 on the grounds that Appellant failed to exhaust his administrative remedies.Appellant’s employment with the Division of Alcohol and Tobacco Control was terminated following a disciplinary action. Appellant filed a complaint with the Administrative Hearing Commission. The Commission dismissed the complaint, finding that Appellant was not a merit employee entitled to a hearing before the Commission and that the Division had internal appeal procedures for its employees. Thereafter, Appellant filed an amended petition for review. The circuit court dismissed the petition with prejudice because Appellant failed to exhaust his administrative remedies. The Supreme Court affirmed, holding that the circuit court properly dismissed Appellant’s action because it lacked authority to review the Division’s administrative decision as a “contested case” pursuant to Mo. Rev. Stat. 536.100, as alleged in the first amended petition. View "Nowden v. Division of Alcohol & Tobacco Control, Missouri Department of Public Safety" on Justia Law