Justia Missouri Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of unlawful possession of a firearm, holding that, by pleading guilty, Defendant waived his argument that the amended complaint and indictment charging him with unlawful possession of a firearm failed to allege the essential element of a prior “conviction.”Defendant pleaded guilty to unlawful possession of a firearm, possession of marijuana, and possession of drug paraphernalia. The circuit court found Defendant’s plea was voluntary, there was a factual basis for the plea, and Defendant was guilty beyond a reasonable doubt. On appeal, Defendant argued that his Oklahoma deferred judgment did not qualify as a “conviction” pursuant to Mo. Rev. Stat. 571.070, and that this argument challenged the sufficiency of the charging documents and, therefore, was not barred by his guilty plea. The Supreme Court disagreed, holding that Defendant’s unconditional guilty plea waived his argument on appeal. View "State v. Rohra" on Justia Law

The Supreme Court reversed the judgment of the circuit court dismissing Petitioner’s petition alleging that the debt collection actions of the owners and operators of LifeSmile Dental Care (collectively, LifeSmile) and attorney Dennis Barton (collectively, Respondents) violated the Fair Debt Collection Practices Act (FDCPA) and that Barton violated the Missouri Merchandising Practices Act (MMPA).The circuit court concluded (1) Petitioner’s FDCPA claim was barred by the statute of limitations, and (2) Petitioner's MMPA claim failed to state a claim because Barton’s collection activities were not “in connection with” the sale of LifeSmile’s dental services to Petitioner, and no lender-borrower relationship existed between Barton and Petitioner. The Supreme Court reversed, holding (1) an FDCPA violation is not time-barred simply because it restates or relates back to assertions made in a debt collection action that is beyond the one-year statute of limitations, and Petitioner identified three actions he alleged amounted an FDCPA violation occurring within a year of his filing of the action; and (2) Barton’s efforts to collect payment were an attempt to complete the transaction of the sale of dental services to Petitioner and were therefore “in connection with” the sale. View "Jackson v. Barton" on Justia Law

The Supreme Court made permanent a preliminary writ of prohibition sought by Relators prohibiting Respondent, the Honorable James F. Kanatzar, from taking any action other than granting their motion to dismiss the underlying wrongful death suit as barred by the statute of limitations.After Plaintiffs filed wrongful death claims against Relators, Relators filed a motion to dismiss on the grounds that the claims were time-barred under the three-year statute of limitations in Mo. Rev. Stat. 537.100 and the savages provision was not applicable. The circuit court overruled the motion to dismiss. Thereafter, Relators filed a petition for writ of prohibition. The Supreme Court granted the writ, holding that because Plaintiffs’ third action was not filed within one year of the nonsuit of their first action - the only action filed within the limitations period - the savings provision did not apply and the third suit was time-barred. View "State ex rel. Goldsworthy v. Honorable James F. Kanatzar" on Justia Law

The Supreme Court made permanent preliminary writs of prohibition sought by Relators to prevent the circuit court from taking any action other than vacating its orders overruling their respective motions to dismiss on the grounds that Plaintiff’s Missouri Human Rights Act (MHRA) claims against them for discrimination and retaliation were time barred.After Relators each filed a motion to dismiss as time barred Alicia Mulvey’s MHRA claims for discrimination and retaliation, Mulvey filed a motion for leave to amend her petition to include common law claims of negligence and wrongful discharge. The circuit court overruled Relators’ motions to dismiss and sustained Mulvey’s motion for leave to amend. The Supreme Court held that the circuit court exceeded its authority when it overruled Relators’ motions to dismiss for failure to state a claim and abused its discretion when it sustained Mulvey’s motion for leave to amend her petition because Mulvey failed to file her MHRA claim within the ninety-day statutory period and her common law claims of negligence and wrongful discharge were fully encompassed and comprehended by the MHRA. View "State ex rel. Church & Dwight Co. v. Honorable William B. Collins" on Justia Law

The Supreme Court affirmed the judgment of the circuit court granting summary judgment in favor of the State on Plaintiff’s action seeking a declaration that the State could not enforce Mo. Rev. Stat. 571.707 against him without violating Mo. Const. art. I, 23 and the Second Amendment to the United States Constitution.Plaintiff, a convicted felon who had completed his sentences, was required to surrender his federal firearms license, class 01 after the General Assembly, in 2008, amended section 571.070 to make it unlawful for any person who has been convicted of a felony to possess a firearm. Plaintiff filed a declaratory judgment action raising facial and as-applied challenges to section 571.070. The circuit court rejected the State’s argument that Plaintiff’s claims were not ripe and found that section 571.070 did not violate the Missouri or United States Constitutions because felons categorically are removed from the group of people who can claim the protections of those constitutional provisions. The Supreme Court affirmed, holding (1) Plaintiff satisfied the requirements to bring a pre-enforcement declaratory judgment action challenging the constitutional validity of section 571.070; and (2) section 571.070 withstands constitutional scrutiny. View "Alpert v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court granting summary judgment in favor of the State on Plaintiff’s action seeking a declaration that the State could not enforce Mo. Rev. Stat. 571.707 against him without violating Mo. Const. art. I, 23 and the Second Amendment to the United States Constitution.Plaintiff, a convicted felon who had completed his sentences, was required to surrender his federal firearms license, class 01 after the General Assembly, in 2008, amended section 571.070 to make it unlawful for any person who has been convicted of a felony to possess a firearm. Plaintiff filed a declaratory judgment action raising facial and as-applied challenges to section 571.070. The circuit court rejected the State’s argument that Plaintiff’s claims were not ripe and found that section 571.070 did not violate the Missouri or United States Constitutions because felons categorically are removed from the group of people who can claim the protections of those constitutional provisions. The Supreme Court affirmed, holding (1) Plaintiff satisfied the requirements to bring a pre-enforcement declaratory judgment action challenging the constitutional validity of section 571.070; and (2) section 571.070 withstands constitutional scrutiny. View "Alpert v. State" on Justia Law