Justia Missouri Supreme Court Opinion Summaries

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

Despite the recent amendments to rent and possession suits, the legislature’s removal of the right to a trial de novo with the possibility of a jury at the circuit court in rent and possession cases still results in parties having the right to a jury trial in the associate division where the suit was initially filed.The Supreme Court reversed the judgment of the trial court denying Defendant’s request for a jury trial after Defendant was sued by her landlord (Plaintiff) for defaulting on rent payments. The trial court concluded that Defendant was not entitled to a jury trial in light of the 2014 statutory amendments to rent and possession suits under Mo. Rev. Stat. chapter 535. In reversing, the Supreme Court held that parties in rent and possession actions brought under Mo. Rev. Stat. 535.040 are still entitled to a jury trial even after the 2014 amendments. View "Brainchild Holdings, LLC v. Cameron" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing Appellant’s petition seeking declaratory relief, injunctive relief, and damages against his former employer (Employer). After he was terminated, Appellant filed this action alleging that his employment agreement with Employer was void and seeking damages for allegedly wrongfully withheld commissions. Employer moved to dismiss on the ground that the agreement contained a forum selection clause providing that the sole proper jurisdiction and venue to interpret and enforce the terms of the agreement shall be the district court of Johnson County, Kansas. The circuit court dismissed the petition without prejudice. The Supreme Court affirmed, holding that the circuit court did not err in enforcing the forum selection clause in the agreement and dismissing the petition without prejudice. View "Reed v. Reilly Co., LLC" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of first-degree murder, felony abuse of a child, and forcible sodomy. The circuit court sentenced Defendant to life imprisonment without the possibility of parole for murder and to consecutive sentences of life imprisonment for felony child abuse and forcible sodomy. The Supreme Court held that the circuit court did not abuse its discretion in (1) admitting evidence of Defendant’s juvenile adjudication for lewd and lascivious conduct with a minor; and (2) admitting evidence that pornographic websites were viewed on Defendant’s cellular telephone and computer. View "State v. Prince" on Justia Law

The Supreme Court granted mandamus relief to Relator, who sought to resign, revoke, or withdraw the circuit court’s medical authorization order authorizing the release of the decedent’s medical records, holding that the medical authorization order in this case was prohibited by this court’s precedent.Relator filed a wrongful death action against Defendants after his brother, the decedent, died allegedly from metastatic colon cancer. During discovery, Defendants sought an order from the circuit court authorizing the release of the decedent’s medical records. The circuit court signed an order authorizing the release of medical records. Relator then petitioned for this writ to prohibit the use of the decedent’s unlimited medical records. The Supreme Court granted a writ of prohibition, holding that the medical authorization was prohibited because there was no case-by-case review of the medical authorization designed to tailor the requests to the pleadings. View "State ex rel. Fennewald v. Honorable Patricia S. Joyce" on Justia Law

The Supreme Court declined to grant mandamus relief to the Regional Convention and Sports Complex Authority, which sought a writ to compel the circuit court to stay arbitration of the Authority’s claims in its petition for a declaratory judgment and to reinstate the cause on the circuit court’s docket.The Authority, which leased a training facility to the St. Louis Rams, LLC, filed a three-count petition for declaratory judgment against the Rams seeking to void provisions in the lease. The Rams filed a motion to compel arbitration, asserting that the Authority’s claims fell within the scope of the lease’s arbitration provisions. The circuit court sustained the Rams’ motion to compel arbitration. In this original action, the Supreme Court held that the parties’ intent to arbitrate disputes involving the lease was clear and that any doubt as to arbitrability must be resolved in favor of the application of the arbitration clause. View "State ex rel. Regional Convention & Sports Complex Authority v. Honorable Michael D. Burton" on Justia Law

The Supreme Court granted writs of prohibition directing the circuit court to vacate its orders sustaining Mo. Sup. Ct. R. 29.12(b) motions and amending the stealing convictions and sentences of Jesse Nelson and Jack Walker II, holding that the circuit court lacked jurisdiction to adjudicate the Rule 29.12(b) motions and amend the judgments.Nelson and Walker pleaded guilty to the class C felony of stealing property worth $500 or more. Both defendants were placed on probation. The Supreme Court subsequently held that the offense of stealing could not be enhanced to a felony pursuant to Mo. Rev. Stat. 570.030.3(1). Thereafter, Nelson and Walker filed motions pursuant to Rule 29.12(b) seeking to amend their convictions and sentences to reflect that stealing property worth $500 or more was a class A misdemeanor. The circuit court sustained the motions and amended the judgments in both cases. The prosecuting attorney sought writs of prohibition directing the circuit court to vacate its orders. The Supreme Court granted the requested relief, holding that the plaint language of Rule 29.12(b) does not provide for an independent post-sentence procedure, and therefore, the circuit court’s action taken after imposing the sentences was a nullity and void. View "State ex rel. Zahnd v. Honorable James W. Van Amburg" on Justia Law