Justia Missouri Supreme Court Opinion Summaries

This original proceeding in certiorari stemmed from George Fisher’s pleas of not guilty by reason of mental disease or defect (NGRI) in two separate cases, one originating in Audrain County and the other in Jackson County. Fisher filed a petition for a writ of habeas corpus challenging his commitment to the Department of Mental Health (DMH) and alleging that the NGRI pleas entered in both cases were deficient. The circuit court granted habeas relief, concluding that the NGRI pleas were deficient. The Supreme Court (1) declared moot the record granting habeas relief in one case given the prosecutor’s nolle prosequi filing in the underlying criminal case; and (2) quashed the record granting habeas relief in the other case, holding that the circuit court abused its discretion by granting relief on the theory that Fisher failed to sign the NGRI notice. View "State ex rel. Hawley" on Justia Law

Defendant filed a Mo. R. Crim. P. 29.15 motion for post-conviction relief approximately sixteen months after the court of appeals issued its mandate affirming Defendant’s conviction for first-degree robbery, despite the rule’s requirement that it be filed within ninety days of the mandate’s issuance. The motion court overruled the motion without an evidentiary hearing on the grounds of untimeliness. The Supreme Court reversed, holding (1) although Defendant filed an untimely Rule 29.15 motion, his untimeliness was excused because the circuit court misinformed him about the appropriate deadlines to file his motion during his sentencing colloquy; and (2) the motion court clearly erred in overruling the Rule 29.15 motion because Defendant demonstrated he was entitled to an evidentiary hearing concerning his ineffective assistance of counsel claim. View "Watson v. State" on Justia Law

Petitioner, who ran a kennel, filed a petition against the Humane Society of the United States and Missourians for the Protection of Dogs alleging that various statements made in documents related to the ballot initiative entitled the Puppy Mill Cruelty Prevention Act were defamatory and placed her in a false light. The circuit court dismissed the petition on the grounds that the statements were absolutely privileged opinions and because Petitioner failed to plead any facts cognizable under a false light cause of action. The Supreme Court affirmed, holding that the circuit court did not err in dismissing the petition because none of the statements pleaded in the defamation claims were actionable as a matter of law and because Petitioner did not plead any facts cognizable in a false light claim. View "Smith v. Humane Society of the United States" on Justia Law

After a jury trial, Appellant was convicted of two counts of murder in the first degree for shooting and killing two deputies. Appellant was sentenced to death. Appellant’s convictions were affirmed on direct appeal. Thereafter, the motion court granted Appellant post-conviction relief and remanded the case for a new penalty phase. After the penalty phase retrial, the jury recommended that Appellant be sentenced to death on each count. The trial court sentenced Appellant in accordance with the jury’s recommendation. Appellant’s death sentences were affirmed on direct appeal. Appellant then filed a Mo. R. Crim. P. motion for post-conviction relief, alleging several claims of ineffective assistance of trial and appellate counsel. The motion court overruled the motion. The Supreme Court affirmed, holding that the motion court did not clearly err in finding that Appellant failed to establish that he was provided ineffective assistance of trial or appellate counsel. View "Tisius v. State" on Justia Law

After a jury trial, Appellant was convicted of three counts of robbery in the first degree, three counts of armed criminal action, and one count of resisting arrest. Appellant’s convictions and sentences were affirmed on direct appeal. Appellant subsequently filed a timely pro se motion for post-conviction relief under Mo. R. Crim. P. 29.15. After Appellant’s public defender entered his appearance, post-conviction counsel filed an amended motion on Movant’s behalf, asserting that trial counsel provided ineffective assistance. The motion court denied relief without an evidentiary hearing. The Supreme Court reversed in part and affirmed in all other respects, holding (1) Appellant’s amended motion for post-conviction relief was timely filed; and (2) the motion court clearly erred in denying relief on Appellant’s pro se claims based on a finding of illegibility. Remanded. View "Creighton v. State" on Justia Law

Plaintiffs filed an action challenging the Joint Committee on Administrative Rules’ (JCAR) authority to disapprove the “geographic sourcing” provisions of a 2010 rule promulgated by the Public Service Commission (PSC). Defendants argued that the case was moot because the PSC voluntarily withdrew the geographic sourcing provisions before the 2010 rule was published. The trial court initially granted the PSC’s motion for summary judgment. After Plaintiffs appealed, the PSC promulgated a 2015 rule that never contained geographic sourcing provisions. The circuit court subsequently dismissed the motion as moot because the 2015 rule did not have geographic souring provisions and the 2010 had been superseded and was no longer in effect. The Supreme Court affirmed, holding that, in light of the adoption of the 2015 rule, no purpose would be served by addressing JCAR’s actions regarding a superseded prior rule. View "State ex rel. Missouri Coalition for the Environment v. Joint Committee on Administrative Rules" on Justia Law

After a jury trial, Appellant was convicted of murder in the first degree and armed criminal action. Appellant’s convictions and sentences were affirmed on direct appeal. Appellant later filed a pro se motion for post-conviction relief. After Appellant’s public defender entered his appearance, post-conviction counsel filed an amended motion on Appellant’s behalf. The motion court denied relief. The Supreme Court affirmed the judgment denying Appellant’s motion for post-conviction relief, holding (1) Appellant’s amended motion for post-conviction relief was timely filed; and (2) trial counsel was not ineffective. View "Hopkins v. State" on Justia Law

Wife appealed the trial court’s judgment dissolving her marriage to Husband, challenging the court’s distribution of marital property. The Supreme Court affirmed, holding that the trial court (1) equitably divided the marital assets and debts in a manner that is definite and capable of enforcement; (2) did not err in assigning no present value to Husband’s defined benefit pension plan through the Missouri Local Government Employees Retirement Benefit Plan; and (3) properly considered the factors in Mo. Rev. Stat. 452.330 and did not err in ordering Wife to pay Husband an equalization share. View "Landewee v. Landewee" on Justia Law

A Bank provided loans to owners of eight condominium units. All eight owners became delinquent on their loans to the Bank and failed to make timely payments on the property owners’ association’s (POA) assessments. The Bank foreclosed on its deeds of trust and purchased all eight properties. The POA demanded payment from the Bank for all new assessments on the properties it purchased and demanded that the Bank pay past due assessments. The Bank sought relief by filing a declaratory judgment action and an action for monetary damages caused by the POA’s alder of the Bank’s title to the properties. The trial court entered partial summary judgment in favor of the Bank, declaring that the Bank was not obligated to pay past due assessments by the POA on properties the Bank purchased at a foreclosure sale. The trial court certified its order for immediate appeal and reserved judgment on Bank’s slander of title count. The POA appealed. The Supreme Court dismissed the appeal, holding that it lacked the authority to review the trial court’s partial judgment because the judgment did not dispose of a distinct judicial unit, and therefore, it was not a final judgment for purposes of Mo. Rev. Stat. 512.020(5). View "First National Bank of Dieterich v. Pointe Royale Property Owners' Association, Inc." on Justia Law

Owners Insurance Company issued Vicki and Chris Craig a policy with underinsured motorist (UIM) coverage. Vicki was injured in an accident when her vehicle was struck by a vehicle driven by another motorist. Vicki incurred damages exceeding $300,000. Shelter Insurance, which insured the at-fault motorist, paid the Craigs $50,000. The Craigs then sought from Owners $250,000, the declarations listed UIM limit amount. Owners paid the Craigs $200,000, citing the off-set provisions that allowed them to deduct the amount paid by Shelter. Thereafter, Owners sought a declaratory judgment over the disputed $50,000. The circuit court ruled that the policy was ambiguous and entered summary judgment in favor of the Craigs. The Supreme Court reversed, holding that the policy unambiguously provides for the $50,000 set-off, that the policy never promised to pay up to the full amount listed in the declarations, and that the declarations did not promise coverage. Remanded. View "Owners Insurance Co. v. Craig" on Justia Law