Justia Missouri Supreme Court Opinion Summaries

Bowman pleaded guilty to one misdemeanor count of receiving stolen property. Although restitution was not originally a condition of Bowman’s probation, the State filed a motion to modify Bowman’s probation by adding a condition of restitution. The State alleged that Bowman should pay the victim to compensate her for the items that were stolen from her apartment but not recovered from Bowman. The trial court granted the State’s motion and modified the terms of Bowman’s probation to add a condition that he pay the requested restitution. Bowman sought a writ of prohibition, arguing that the trial court lacked authority to add the restitution condition because Mo. Rev. Stat. 559.105.1 only authorizes restitution for losses connected to the offense for which he was charged - possession of stolen property. The Supreme Court issued a preliminary writ of prohibition, which it made permanent, holding that because the State failed to show that the victim’s unrecovered losses were “due to” Bowman’s offense, the trial court lacked the authority to require Bowman to require restitution as to these losses as a condition of his probation. View "State ex rel. Bowman v. Honorable Inman" on Justia Law

When William Fleming failed to pay his court costs within the first three years of his probation, Fleming’s probation was revoked and execution of his concurrent seven-year sentences was ordered. Fleming filed a petition for writ of habeas corpus, arguing that the sentencing court violated his due process and equal protection rights by revoking his probation solely because he was indigent. The Supreme Court issued a writ of habeas corpus, holding that the sentencing court’s revocation of Fleming’s probation violated Fleming’s Fourteenth Amendment rights because the court failed to inquire into the reasons for Fleming’s failure to pay his court costs. View "State ex rel. Fleming v. Missouri Board of Probation & Parole" on Justia Law

Charles Zimmerman filed a petition for writ of prohibition to prevent the circuit court from holding a revocation hearing. The court of appeals denied the writ. Zimmerman then filed a writ petition with the Supreme Court. While the writ was pending, the circuit court held Zimmerman’s probation revocation hearing and concluded that Zimmerman violated the terms of his probation. The Supreme Court subsequently issued a preliminary writ of prohibition commanding the circuit court to take no further action in the matter. Zimmerman argued that the circuit court had no authority over him under Mo. Rev. Stat. 559.036.8 because his probation terminated by operation of law years before the probation revocation hearing. The Supreme Court made the preliminary writ in prohibition permanent and directed the circuit court to discharge Zimmerman from probation, holding that the circuit court abused its discretion and exceeded its authority in holding Zimmerman’s probation revocation hearing because it failed to make every reasonable effort to conduct a hearing prior to the expiration of the probationary period. View "State ex rel. Zimmerman v. Honorable David Dolan" on Justia Law

Shelter Mutual Insurance Company issued the Swadley family a policy with underinsured motorist (UIM) coverage. The policy’s declarations page listed “100,000 Per Person” as the UIM limit. After Angela Swadley was killed in a collision, the Swadleys made a claim to Shelter pursuant to their policy’s UIM coverage. When Shelter denied the claim, the Swadleys filed a petition against Shelter. The circuit court ruled that the policy was ambiguous, entered partial summary judgment in favor of the Swadleys and awarded the Swadleys $100,000. The Supreme Court reversed, holding that the policy unambiguously precluded UIM coverage from applying to the Swadleys’ claim. View "Swadley v. Shelter Mutual Insurance Co." on Justia Law

After a jury trial, Defendant was convicted of first-degree burglary, misdemeanor stealing, and driving while revoked. Defendant appealed, arguing that there was insufficient evidence to support his conviction for first-degree burglary and that the circuit court abused its discretion by admitting testimony that demonstrated Defendant’s propensity to engage in criminal activity. The Supreme Court affirmed, holding (1) there was sufficient evidence to convict Defendant of first-degree burglary; and (2) the circuit court did not abuse its discretion in admitting the evidence of uncharged misconduct on the basis that it had a “legitimate tendency to directly establish the defendant’s guilty of the charge for which he [was] on trial.” View "State v. Naylor" on Justia Law

When Child was not yet one year old, Grandfather filed a petition to establish a guardianship and conservatorship jointly in two cousins, alleging that Mother was unable or unfit to assume the duties of guardianship. After a hearing, the trial court found Mother unable and unfit to properly care for Child and ordered the issuance of letters of guardianship and conservatorship to the two cousins as co-guardians. Mother appealed, arguing that the trial court had utilized the wrong burden of proof and that due process requires proof of unfitness by clear and convincing evidence. The Supreme Court affirmed, holding (1) Mo. Rev. Stat. 475.030.4 requires proof of inability or unfitness by a preponderance of the evidence, and Mother failed to preserve her argument that the statute is unconstitutional; (2) the trial court’s judgment ordering the issuance of letters of guardianship and conservatorship was supported by substantial evidence and was not against the weight of the evidence; and (3) the trial court did not abuse its discretion in overruling Mother’s motion for a continuance. View "In re A.L.R." on Justia Law

Missouri American Water Company (MAWC) filed a petition to charge an infrastructure system replacement surcharge to its St. Louis County customers. The Public Service Commission (PSC) approved the petition. The Office of the Public Counsel appealed, arguing that the PSC lacked the authority to grant the petition because St. Louis County did not meet Mo. Rev. Stat. 393.1000-393.1006’s threshold population requirement at the time PSC approved the surcharge. The Office of the Public Counsel appealed. While the appeal was pending, MAWC and PSC reached an agreement establishing a new rate base that incorporated the costs of the MAWC projects for all then-existing surcharges. The Supreme Court dismissed this case as moot, holding (1) because the surcharge is no longer in effect and no effective relief may be granted, the issue as to whether MAWC can utilize the surcharge provisions of section 393.1003 is moot; and (2) the issues presented on appeal did not meet the requirements for an exception to the mootness doctrine. View "In re Petition of Missouri-American Water Company for Approval to Change its Infrastructure System Replacement Surcharge" on Justia Law

After a jury trial, Appellant was found guilty of second-degree statutory rape and the class D felony of incest. Appellant’s convictions and sentences were affirmed. Appellant later filed a pro se motion for postconviction DNA testing pursuant to Mo. Rev. Stat. 547.035. The circuit court overruled and denied Appellant’s motion. Appellant was not notified of any proceedings in his case and requested additional information. The circuit court failed to provide the requested information. On appeal, the court of appeals, sua sponte, determined that it did not have jurisdiction to consider the appeal because the circuit court’s docket entry was not denominated a judgment. The Supreme Court granted transfer and reversed and remanded, holding that there could be no meaningful appellate review due to the circuit court’s failure to issue findings of fact and conclusions of law as required by Mo. Rev. Stat. 547.035.8. View "Mercer v. State" on Justia Law

St. Louis City’s Ordinance 70078 establishes a citywide local minimum wage. The trial court invalidated the Ordinance because it requires a higher minimum wage than the state requires in Mo. Rev. Stat. 290.502. In so ruling, the trial court concluded that Mo. Rev. Stat. 71.010, which includes a general prohibition on local laws that conflict with state laws, would bar such supplemental local minimum wage ordinances. The Supreme Court reversed the portion of the judgment invalidating Ordinance 70078, holding (1) the trial court correctly found that Mo. Rev. Stat. 67.1571 does not preempt Ordinance 70078 because section 67.1571 was enacted in a manner that violates Mo. Const. art. III, 23; (2) Missouri’s minimum wage law does not occupy the field of minimum wage laws, nor does it prohibit the adoption of local minimum wage ordinances such as Ordinance 70078; and (3) Ordinance 70078 is within the municipality’s police powers, and the City did not exceed its authority in enacting the minimum wage ordinance. View "Cooperative Home Care, Inc. v. City of St. Louis" on Justia Law

David DePriest and Natalie DePriest, brother and sister, were charged separately with offenses arising from their cultivation of marijuana plants. The DePriests were represented by the same counsel throughout their separate criminal proceedings. The DePriests jointly pleaded guilty pursuant to a plea deal on counsel’s recommendation. The trial court accepted both DePriests’ pleas. Thereafter, the DePriests filed separate motions for postconviction relief pursuant to Mo. R. Crim. P. 24.035, alleging ineffective assistance of counsel because defense counsel continued to represent both of them long after it became clear during the plea negotiations that there was an actual conflict of interest between them. The motion court denied both motions without an evidentiary hearing. The Supreme Court vacated the motion court’s judgments and remanded the cases for further proceedings, holding that both David and Natalie alleged sufficient facts to state a claim of ineffective assistance of counsel under Rule 24.035, and therefore, the motion court erred in denying the DePriests an evidentiary hearing. Remanded. View "DePriest v. State" on Justia Law