Justia Missouri Supreme Court Opinion Summaries

Shannon Dodson died as a result of a dissection of her left main coronary artery during a cardiac catheterization. Dodson’s family (Plaintiffs) brought a wrongful death action against the physician who treated Dodson and his employer (collectively, Defendants). The jury returned a verdict in the amount of almost $2 million for economic damages and $9 million for noneconomic damages. The trial court reduced the noneconomic damages to $350,000 pursuant to Mo. Rev. Stat. 538.210(1). Both parties appealed. The Supreme Court affirmed, holding (1) the section 538.210 noneconomic damages cap does not violate the separation of powers principle, equal protection, or the right to trial by jury in wrongful death cases; (2) the trial court did not err in granting a directed verdict on the issue of aggravating circumstances damages at the close of Defendants’ evidence; and (3) there was no error in Defendants’ other issues on appeal. View "Dodson v. Ferrara" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and multiple counts of first-degree assault, forcible rape, and forcible sodomy. Appellant was sentenced to death for the murder. The Supreme Court affirmed. Appellant subsequently filed a motion for post-conviction relief pursuant to Mo. R. Crim. P. 29.15, raising a number of additional ineffective assistance of counsel claims and arguments related to suppression issues presented at trial. After an evidentiary hearing, the motion court overruled Appellant’s motion. The Supreme Court affirmed, holding that the motion court did not clearly err in overruling the entirety of Appellant’s rule 29.15 motion for post-conviction relief. View "Davis v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and multiple counts of first-degree assault, forcible rape, and forcible sodomy. Appellant was sentenced to death for the murder. The Supreme Court affirmed. Appellant subsequently filed a motion for post-conviction relief pursuant to Mo. R. Crim. P. 29.15, raising a number of additional ineffective assistance of counsel claims and arguments related to suppression issues presented at trial. After an evidentiary hearing, the motion court overruled Appellant’s motion. The Supreme Court affirmed, holding that the motion court did not clearly err in overruling the entirety of Appellant’s rule 29.15 motion for post-conviction relief. View "Davis v. State" on Justia Law

In 2012, IBM Corp. filed a use tax return for its sales of hardware and software to MasterCard International, LLC for MasterCard’s use in processing credit and debt card transactions, claiming that the equipment it sold to MasterCard was exempt from use tax because MasterCard’s activities qualify as “manufacturing” under Mo. Rev. Stat. 144.054.2. The Administrative Hearing Commission granted IBM a refund, finding that MasterCard’s use of the hardware and software qualified as “manufacturing a product” as that term is used in the tax exemption set out in the statute. The Supreme Court reversed, holding that MasterCard’s use of the hardware and software does not qualify as the “manufacturing of any product” under section 144.054.2, and therefore, IBM is not entitled to an exemption from use tax. View "IBM Corp. v. Dir. of Revenue" on Justia Law

The Macon County Emergency Services Board (Board) filed a petition for declaratory judgment against the Macon County Commission (Commission) seeking a judgment that it was entitled to receive a share of Mason County’s use tax revenue proportionate to its share of the county sales tax revenue. The circuit court denied the Board’s request. The Supreme Court affirmed, holding that because Mo. Rev. Stat. 144.757 does not direct third-class counties as to the disbursement of county use tax revenue, it is within the discretion of the Commission whether to share that revenue with the Board. View "Macon County Emergency Servs. Bd v. Macon County Comm’n" on Justia Law

Appellant filed suit alleging that Respondents - Odessa Gun & Pawn, Charles Doleshal, and Derrick Dady - negligently sold or entrusted a gun to Appellant’s mentally ill daughter, who used the gun to kill Appellant’s husband. Appellant alleged claims for negligence, negligent entrustment, and negligence per se. The circuit court entered summary judgment in favor of Respondents, concluding (1) Appellant’s negligence claim was preempted by the Protection of Lawful Commerce in Arms Act (PLCAA), (2) Appellant’s negligent entrustment claim failed to state a claim, and (3) Appellant’s individual claims against Doleshal and Dady were moot. The Supreme Court reversed the judgment to the extent it precluded Appellant from proceeding with her negligent entrustment claim but otherwise affirmed, holding that the trial court (1) did not err by entering judgment for Respondents on Appellant’s negligence claim, as the PLCAA is constitutional and preempts Appellant’s negligence claim; (2) erred in granting judgment in favor of Respondents on Appellant’s claim for negligent entrustment, as this claim is not preempted by the PLCAA and is recognized by Missouri law; and (3) erred in granting summary judgment on Appellant’s individual claims for negligent entrustment, as these claims are viable. Remanded. View "Delana v. CED Sales, Inc." on Justia Law

Office Depot, Inc., which is incorporated in the state of Delaware and headquartered in Florida, contracts with a printer to have catalogs printed in Illinois and Indiana. The Postal Service delivers the catalogs to customers in Missouri. Office Depot accrued and paid almost $85,000 in Missouri use tax based on the cost of the printed catalogs between 2008 and 2010. Office Depot filed an application for use tax refund for the amount it paid. The Director of Revenue denied Office Depot’s refund claim. The Administrative Hearing Commission reversed, finding that Office Depot was entitled to a full refund because use tax may be imposed only if Office Depot used the catalogs in Missouri but that Office Depot did not. The Supreme Court affirmed, holding that Office Depot did not exercise any right or power incident to ownership or control over the catalogs in Missouri, and therefore, it did not “use” the catalogs in Missouri. Consequently, Office Depot was entitled to a refund of use tax under the use tax statute. View "Office Depot, Inc. v. Dir. of Revenue" on Justia Law

Plaintiffs filed suit against four City of Grandview police officers alleging wrongful arrest, battery, malicious prosecution and negligence. Plaintiffs joined the City, alleging that the City was vicariously liable for the officers’ actions because the City had purchased an insurance policy that contained a provision for law enforcement liability coverage, which coverage waived the City’s rights to sovereign immunity. The City moved for summary judgment, asserting that the insurance policy disclaimed coverage for any actions that would be prohibited by sovereign immunity. The circuit court overruled the motion. Thereafter, the City sought a writ of prohibition. The court of appeals denied the writ. The City subsequently sought a writ of prohibition from the Supreme Court. The Court issued a preliminary writ of prohibition that it made permanent, holding that because the insurance policy expressly disclaimed a waiver of sovereign immunity and provided coverage to the City only for those claims for which sovereign immunity has been statutorily waived, the City did not waive sovereign immunity. View "State ex rel. City of Grandview v. Hon. Jack R. Grate" on Justia Law

After a jury trial, Defendant was found guilty of murdering his aunt, uncle, and their granddaughter. The trial court sentenced Defendant to death on all three counts of first-degree murder. The Supreme Court affirmed, holding that the trial court did not err by (1) rejecting Defendant’s proffered jury instruction for felony murder in the second degree; (2) admitting testimony from the State’s cell phone analyst and the State’s fingerprint analyst; (3) excluding testimony and argument that another individual had motive and opportunity to commit the murders; (4) excluding evidence of a witness’s alleged bias against a potential witness; and (5) denying Defendant’s mistrial requests when the State inadvertently showed crime scene photographs of the victims. View "State v. Blurton" on Justia Law

After a jury-waived trial, Defendant was convicted of recklessly exposing another to HIV without that person’s knowledge and consent pursuant to Mo. Rev. Stat. 191.677. Defendant was sentenced to seven years’ imprisonment. Defendant appealed, arguing that, by compelling her to disclose to potential sexual partners that she has HIV, section 191.677 infringes on her constitutional rights to free speech and privacy. The Supreme Court affirmed, holding (1) although section 191.677 may compel individuals with HIV to disclose that they have HIV under certain circumstances, the statute imposes only incidental burdens on speech and does not violate constitutional provisions protecting the freedom of speech; and (2) because section 191.677 does not criminalize consensual, non-harmful sexual conduct, Defendant’s right to privacy argument fails. View "State v. S.F." on Justia Law