Justia Missouri Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the Administration Hearing Commission (AHC) affirming the Missouri Ethics Commission’s (MEC) imposition of fees arising from the failure to Robin Wright-Jones and Wright-Jones for Senate (collectively, Appellants) to comply with the rules of Mo. Rev. Stat. chapter 130. The court also affirmed the judgment of the circuit court finding that Mo. Rev. Stat. 105.961.4(6) was not unconstitutional. On appeal, Appellants claimed that the monetary fees assessed by the MEC violated Mo. Const. art. I, section 31. Specifically, Appellants argued that, pursuant to section 105.961.4(6), the MEC may not assess fines for violations of state statutes, regulations, or rules. The Supreme Court disagreed, holding (1) there was no improper delegation of authority to the MEC; (2) the AHC’s decision was supported by the record; and (3) the assessed fees were not excessive. View "Wright-Jones v. Missouri Ethics Commission" on Justia Law

The Supreme Court affirmed the decision of the Administration Hearing Commission (AHC) affirming the Missouri Ethics Commission’s (MEC) imposition of fees arising from the failure to Robin Wright-Jones and Wright-Jones for Senate (collectively, Appellants) to comply with the rules of Mo. Rev. Stat. chapter 130. The court also affirmed the judgment of the circuit court finding that Mo. Rev. Stat. 105.961.4(6) was not unconstitutional. On appeal, Appellants claimed that the monetary fees assessed by the MEC violated Mo. Const. art. I, section 31. Specifically, Appellants argued that, pursuant to section 105.961.4(6), the MEC may not assess fines for violations of state statutes, regulations, or rules. The Supreme Court disagreed, holding (1) there was no improper delegation of authority to the MEC; (2) the AHC’s decision was supported by the record; and (3) the assessed fees were not excessive. View "Wright-Jones v. Missouri Ethics Commission" on Justia Law

The Supreme Court affirmed the judgment of the circuit court in favor of Plaintiff on her claim of negligence alleging that Defendant, her employer, breached its duty to protect her from the criminal act of a third person on its premises. On appeal, Defendant argued that the circuit court erred in submitting a verdict director to the jury that was not supported by substantial evidence and erred in allowing Plaintiff to make arguments to the jury that misstated the law as instructed in the verdict director. The Supreme Court held (1) the allegation of error made in Defendant’s first point on appeal was not properly preserved; and (2) Defendant’s remaining arguments on appeal were unavailing. View "Wieland v. Owner-Operator Services, Inc." on Justia Law

The Supreme Court affirmed the judgment of the circuit court in favor of Plaintiff on her claim of negligence alleging that Defendant, her employer, breached its duty to protect her from the criminal act of a third person on its premises. On appeal, Defendant argued that the circuit court erred in submitting a verdict director to the jury that was not supported by substantial evidence and erred in allowing Plaintiff to make arguments to the jury that misstated the law as instructed in the verdict director. The Supreme Court held (1) the allegation of error made in Defendant’s first point on appeal was not properly preserved; and (2) Defendant’s remaining arguments on appeal were unavailing. View "Wieland v. Owner-Operator Services, Inc." on Justia Law

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