Justia Missouri Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of two counts of second-degree murder and two counts of armed criminal action. The court held (1) the circuit court did not err in refusing to instruct the jury on self-defense as to felony murder because, for felony murder, Defendant was not prosecuted for his use of force; and (2) as to Defendant’s argument that the circuit court erred in submitting instructions on the felony murder for the second-degree murder counts, Defendant failed to establish plain error and, furthermore, was not prejudiced. View "State v. Oates" on Justia Law

The Supreme Court affirmed the judgment of the motion court overruling Appellant’s motion for postconviction relief under Rule 29.15, holding that Appellant’s argument that his appellate counsel was ineffective was unavailing.Appellant was convicted of second-degree murder. On appeal, appellate counsel did not raise as points of error the trial court’s rejections of Appellant’s requested jury instructions. In his Rule 29.15 motion for postconviction relief, Appellant argued that his appellate counsel was ineffective for failing to raise these issues. The motion court denied the motion. The Supreme Court affirmed, holding that appellate counsel’s performance was not constitutionally deficient because appellate counsel did not fail to exercise the customary level of skill and diligence of a reasonably competent attorney. View "Meiners v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of first-degree murder and armed criminal action, holding that the circuit court did not err by refusing to submit a self-defense instruction.In State v. Smith, 456 S.W.3d 849, 852 (Mo. 2015), the Supreme Court reaffirmed that if substantial evidence is presented of the elements of self-defense, the issue is injected and self defense must be submitted by instructing the jury that the State has the burden of proving a lack of self-defense beyond a reasonable doubt. In the instant case, the Supreme Court held that the circuit court did not err in refusing the self-defense instruction because Defendant did not meet his burden of producing evidence sufficient to inject self-defense in his case. View "State v. Bruner" on Justia Law

The Supreme Court reversed the order of the motion court overruling Defendant’s Mo. R. Crim. P. 29.15 motion for postconviction relief alleging that he received ineffective assistance of counsel during his criminal proceedings, holding that counsel failed to timely file an amended motion.Defendant was convicted of first-degree robbery, resisting arrest, and second-degree trafficking. After unsuccessfully pursuing an appeal, Defendant filed a pro se motion for postconviction relief under Rule 29.15. A special public defender entered her appearance on Defendant’s behalf and then filed a motion for leave to file amended answer. The motion court granted the motion. The Supreme Court held that Defendant’s counsel untimely filed the amended motion under Rule 29.15, resulting in a presumption of abandonment. The court remanded the matter for a determination of whether Defendant was abandoned. View "Watson v. State" on Justia Law

The Supreme Court reversed the judgment of the circuit court convicting Defendant of the class C felony of possession of a controlled substance, holding that there was insufficient evidence Defendant knew of the presence of the controlled substance for which she was convicted of knowingly possessing.On appeal, Defendant argued that the circuit court erred in overruling her motion for judgment of acquittal and entering judgment and sentence against her because the State did not present sufficient evidence that Defendant knowingly possessed the methamphetamine found by law enforcement officers. The Supreme Court agreed, holding that there was insufficient evidence to establish that Defendant knew or was aware of the methamphetamine recovered by the officers. View "State v. Gilmore" on Justia Law

The Supreme Court affirmed the judgment of the probate division denying the application of Ruth Mickels (“Mickels”) to be appointed as personal representative of the estate of her late husband, Joseph Mickels, Sr. The probate denied the application as untimely under Mo. Rev. Stat. 473.020, which requires all applications to be filed within one year of the decedent’s death. By the time the application was filed, the decedent had been deceased for seven years. On appeal, Mickels argued that Mickels v. Danrad, 486 S.W.3d 327 (Mo. banc 2016) (“Mickels I”), announced a new cause of action previously unavailable in Missouri and that equity required the allowance of an out-of-time appointment. The Supreme Court affirmed, holding that Mickels’s application for appointment as personal representative was time-barred by section 473.020 because (1) Mickels I did not announce a new cause of action; and (2) where the court was obligated to follow the clearly articulated statute of limitations, it could not exercise an equitable powers to provide relief in this case. View "In re Estate of Joseph B. Mickels" on Justia Law

The Supreme Court affirmed the motion court’s judgment dismissing Appellant’s Rule 24.035 motion, which was filed one day late, as untimely.On appeal, Appellant argued that a narrow exception applies to allow the date filing of pro se motions for post-conviction relief because the public defender who assumed the duty of filing the pro se motion actively interfered with the filing of the motion. The Supreme Court affirmed the motion court’s judgment dismissing the motion as untimely, holding that the third-party interference exception did not apply in this case because Appellant did not prepare the motion himself or take any steps to ensure the motion was filed on time. View "Propst v. State" on Justia Law

The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission denying workers’ compensation for the death of Patricia White’s husband, Ulysses. Ulysses suffered a fatal cardiovascular event while at work. The Commission concluded that Patricia had not met her burden of establishing that the cardiovascular event was caused by an accident. Patricia appealed, arguing that the Commission erred by applying the wrong burden of proof to her claims under Mo. Rev. Stat. 287.120 and 287.020. The Supreme Court affirmed, holding that Patricia failed to establish that an accident was the prevailing factor in causing Ulysses’s injury, as required by section 287.020.3(4). View "White v. Conagra Packaged Foods, LLC" on Justia Law

The Supreme Court granted a writ of prohibition sought by Bayer Corporation and related entities (collectively, Bayer) directing the circuit court to dismiss nonresident Plaintiffs’ claims in a petition alleging personal injures from Essure, a female contraceptive device Bayer manufactures and distributes. Specifically, Bayer alleged that Missouri had no specific personal jurisdiction over eighty-five out of ninety-two plaintiffs, who were nonresidents of Missouri and did not allege that their injury occurred in Missouri. The Supreme Court vacated the circuit court’s order overruling Bayer’s motion to dismiss, holding that the petition did not assert any recognized basis for personal jurisdiction over Bayer with respect to nonresident Plaintiffs. View "State ex rel. Bayer Corp. v. Honorable Joan L. Moriarty" on Justia Law

Article I, section 35 of the Missouri Constitution, which protects “the right of farmers and ranchers to engage in farming and ranching practices” does not create a new constitutional right to engage in the illegal drug trade.Defendant appealed his convictions of producing more than five grams of marijuana, possession of more than five grams of marijuana with intent to distribute, and possession of drug paraphernalia, arguing that the statutes prohibiting marijuana cultivation and possession violate the constitutional right to farm guaranteed by article I, section 35. The Supreme Court affirmed, holding (1) the plain, ordinary, and natural meaning of article I, section 35 demonstrates no purpose to sub silentio repeal laws criminalizing the cultivation or possession of controlled substances; and (2) Defendant’s marijuana cultivation operation was not a farming practice to be protected by article I, section 35. View "State v. Shanklin" on Justia Law