Justia Missouri Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court quashing its preliminary writ in mandamus and denying Bryan Robison’s request for a permanent writ against the director of the Department of Insurance, Financial Institutions, and Professional Registration (Department), holding that Robison failed to demonstrate he was entitled to mandamus relief.One month before Robison’s license as a general bail bond agent was set to expire, he applied to renew his license with the director of the Department. As a result of Robison’s outstanding forfeitures and judgments, the director denied Robison’s application for renewal. Rather than exercising his right to file a complaint with the Administrative Hearing Commission, Robison filed a petition for a writ of mandamus, alleging that the director denied his renewal application without proper notice and an opportunity to be heard. The circuit court quashed its preliminary writ and denied Robison’s request for a permanent writ of mandamus. The Supreme Court held that the circuit court did not abuse its discretion because the director properly exercised her discretion by refusing the renewal request pursuant to her statutory authority and this Court’s rules. View "State ex rel. Robison v. Lindley-Myers" on Justia Law

In this declaratory judgment action brought against Judge Russell E. Steele and Judge Kristie Swaim challenging two amendments to a consolidation agreement the parties entered into in 2008, the Supreme Court reversed the circuit court’s judgment that these two amendments were invalid and entered judgment for Judge Steele.The consolidation agreement designated Decker as the sole appointing authority for all deputy circuit clerks and division clerks. In 2013, Judge Steele signed an administrative order amending the consolidation agreement and designating the presiding judge of the Second Judicial Circuit as the appointing authority for all deputy and division clerks. In 2014, the Second Judicial Circuit approved an administrative order amending the consolidation agreement to designate Judge Swaim as the sole appointing authority. Plaintiffs filed this declaratory judgment action challenging the validity of the amendments. The circuit court entered judgment for Plaintiffs. The Supreme Court reversed, holding (1) the 2013 and 2014 amendments were made in compliance with the procedures to which Decker consented in voluntarily joining the consolidation agreement; and (2) therefore, Judge Steele held appointing authority over deputy and division clerks from the date of the order adopting the 2013 amendment until the date of the order adopting the 2014 amendment and transferring that authority to Judge Swaim. View "Gall v. Steele" on Justia Law

The Supreme Court affirmed the judgment of the circuit court entering judgment in favor of Sherry Spence on her wrongful death cause of action for the death of her husband.Spence sued BNSF Railway Company for the wrongful death of the decedent, who was killed after a BNSF train struck his pickup truck at a railroad crossing. Spence alleged BNSF was negligent for failing to trim the vegetation around the railroad crossing and asserted a claim of respondeat superior liability against BNSF, alleging that its train crew members were negligent for failing to stop or slow the train. A jury found in favor of Spence, assessing ninety-five percent of the fault to BNSF for the conduct of its train crew and for its failure to maintain the railroad crossing, and five percent of the fault to the decedent. The Supreme Court affirmed, holding that the circuit court did not err in (1) overruling BNSF’s motion for a new trial based upon a juror’s intentional nondisclosures; (2) submitting the verdict directors in two jury instructions and the corresponding verdict form; and (3) overruling BNSF’s motion for a new trial on the grounds that an instruction regarding the duties owed by BNSF was improperly submitted. View "Spence v. BNSF Railway Co." on Justia Law

The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission (Commission) declining to approve the agreement entered into Employer and Employee that Employer would make a lump sum payment to fully satisfy Employee’s award of permanent total disability benefits.Employee received a work-related injury and filed a workers’ compensation claim against Employer. A final award granted Employee permanent total disability benefits to be paid weekly. The parties later agreed that Employee would make a lump sum benefit to fully satisfy the award. The Commission declined to approve the agreement, concluding that the Commission had no authority to approve the agreement either as a settlement under Mo. Rev. Stat. 287.390 or as an application for a “commutation” under Mo. Rev. Stat. 287.530. The Supreme Court affirmed, holding (1) the Commission did not have the authority to consider or approve the agreement under section 287.390; and (2) the Commission properly refused to approve a commutation pursuant to the agreement. View "Dickemann v. Costco Wholesale Corp." on Justia Law

The Supreme Court affirmed the motion court’s judgment overruling Appellant’s Mo. R. Crim. P. 24.035 motion without an evidentiary hearing, holding that the record conclusively refuted the claims made in the motion.Appellant pled guilty to second-degree drug trafficking and was sentenced to fifteen years’ imprisonment. After Appellant violated the conditions of his release, the court revoked Appellant’s probation. Appellant filed a rule 24.035 motion challenging his drug manufacturing conviction and asserting that his plea counsel was ineffective for inducing an involuntary guilt plea. The motion court overruled the motion on the ground that the record conclusively refuted Appellant’s claims. The Supreme Court affirmed, holding that, when looking at the totality of the circumstances, the record conclusively refuted the claims in the amended motion. View "Ryan v. State" on Justia Law

The Supreme Court affirmed an Administrative Hearing Commission (Commission) decision allowing the director of revenue to redistribute tax revenue owed to the City of Lee’s Summit but erroneously paid to Cass County.Cass County sought a writ prohibiting the director of revenue from withholding the tax revenue and redistributing it to Lee’s Summit, arguing that the director lacked the authority to undertake such an action because this was a refund matter and no application for a refund was filed. The court of appeals ruled that a writ was inappropriate because the County had an adequate remedy by appeal to the Commission. On appeal to commission, the County was denied relief. The Supreme Court affirmed, holding that this was not a refund matter contemplated by Mo. Rev. Stat. 144.190.2, and accordingly, the County failed to demonstrate that the Commission's decision was not authorized by law. View "Cass County, Missouri, v. Director of Revenue" on Justia Law

The Supreme Court affirmed as modified the Labor and Industrial Relations Commission’s determination that because Robert Casey’s exposure to asbestos occurred while he was employed by Employer, its insurer (Insurer), was liable to Dolores Murphy, Casey’s widow, for benefits under Mo. Rev. Stat. 287.200.4.Casey died from mesothelioma caused by repeated exposure to asbestos in the workplace. An administrative law judge (ALJ) found Employer liable and awarded section 287.200.4’s enhanced mesothelioma benefits to Murphy and Casey’s eight children. The Commission largely affirmed, limiting recovery to Murphy and determining Murphy to be the sole proper claimant because the amended claim did not identify Casey’s child as dependents or claimants. The Supreme Court modified the Commission’s decision to include Casey’s children in the final award and otherwise affirmed, holding (1) Insurer was liable for the enhanced mesothelioma benefits; (2) section 287.022 is constitutional as applied; and (3) because section 287.200.4 does not limit recovery to dependent children and because the children were properly listed on the amended claim, they should have been included in the final award. View "Accident Fund Insurance Co. v. Casey" on Justia Law

Here, the Supreme Court reaffirmed its decision in Mahoney v. Doerhoff Surgical Services, Inc., 807 S.W.2d 503 (Mo. 1991), upholding the constitutional validity of Mo. Rev. Stat. 538.225’s requirement of an affidavit stating the plaintiff has the opinion of a legally qualified medical provider on the issues of breach of the standard of care and causation of damages in medical malpractice actions.Appellant appealed the dismissal of her medical malpractice case without prejudice for failure to file an affidavit of merit under section 538.225, arguing that the statute’s affidavit requirement violates Missouri’s open courts provision, her right to trial by jury, and the principle of separation of powers under the Missouri Constitution. The Supreme Court affirmed the judgment of the circuit court and reaffirmed the constitutional validity of requiring an affidavit from a qualified health care provider. View "Hink v. Helfrich" on Justia Law

Article I, section 18(c), which voters added to the Missouri Constitution in 2014, does not violate due process.Defendant was convicted of three counts of first-degree statutory sodomy. On appeal, Defendant challenged the constitutionality of article I, section 18(c), arguing that it violates due process because it allows admission of evidence of prior criminal acts in the prosecution’s case-in-chief to prove a defendant has the propensity to commit the charged crime. The Supreme Court held (1) article I, section 18(c) does not violate federal due process on its face; (2) the circuit court is not required to make an express finding of legal relevance before admitting evidence under article I, section 18(c), provided the record reflects a sound basis for the balancing the amendment requires; and (3) the circuit court did not err in admitting evidence of Defendant’s prior criminal act because the danger of unfair prejudice from that evidence did not substantially outweigh its probative value. View "State v. Williams" on Justia Law

At issue was whether the relief ordered by the trial court for the Columbia Police Department’s infringement of Shayne Healea’s attorney-client privilege and violation of his Sixth Amendment rights was adequate.The Department surreptitiously recorded a conversation between Healea and his attorney at the police department. All parties agreed that the recording violated Healea's Sixth Amendment rights and infringed on his attorney-client privilege. After reviewed the recording, a special master found no discussion of trial strategy, but paragraph ten of the master’s report specifically described the substance of questions Healea posed to his attorney. The trial court directed the circuit clerk to unseal the entire report. Healea then sought a writ of prohibition or mandamus to prevent the trial court from unsealing the master’s report. The court of appeals issued a preliminary writ. The Supreme Court made the preliminary writ permanent in part and quashed it in part. The Court ordered that paragraph ten of the report shall be sealed but that the remainder of the report shall remain unsealed, as it contained no confidential statements by Healea. View "State ex rel. Healea v. Honorable Frederick P. Tucker" on Justia Law