Justia Missouri Supreme Court Opinion Summaries

Defendant was charged with first degree assault and an associated armed criminal action count under Mo. Rev. Stat. 571.015.1. Defendant, who was a juvenile at the time of the offenses, moved to dismiss the armed criminal action charge on the ground that the application of the sentencing provisions of section 571.015.1 to juvenile offenders is unconstitutional. The trial court agreed with Defendant, concluding that section 571.015.1 is unconstitutional as applied to all juvenile offenders and declared unconstitutional the three-year mandatory minimum incarceration requirement for juveniles who are certified to stand trial as adults. The State subsequently filed this interlocutory appeal challenging the trial court’s determination regarding the constitutional validity of section 571.015.1. The Supreme Court dismissed the State’s appeal, holding that the State has no right to appeal this interlocutory decision under section 547.200.1, nor does the trial court’s decision constitute a final judgment from which the State is entitled to appeal under section 547.200.2. View "State v. Smiley" on Justia Law

After a jury trial, Defendant was convicted of one count each of burglary in the first degree and an associated count of armed criminal action, attempted robbery in the first degree and an associated count of armed criminal action, assault in the third degree, and resisting arrest for a felony. The Supreme Court affirmed, holding (1) the evidence was sufficient for jury to find beyond a reasonable doubt that Defendant committed armed criminal action in connection with the burglary; (2) there was sufficient evidence to support the the resisting arrest conviction; and (3) the trial court did not err by overruling Defendant’s motion for a continuance. View "State v. Jones" on Justia Law

The City of De Soto and a De Soto resident (collectively, Appellants) filed suit against the governor and attorney general (collectively, Respondents) seeking a declaratory judgment that Mo. Rev. Stat. 321.322.4 violates the prohibition against special laws contained in Mo. Const. art. III, 40. The trial court granted summary judgment in favor of Respondents. The Supreme Court reversed, holding (1) section 321.322.4 is a special law in violation of Mo. Const. art. III, 40; (2) consequently, the State was required to provide a substantial justification for enacting the statute rather than a general law; and (3) because the State offered no such evidence, entry of judgment for the State was error. View "City of DeSoto v. Nixon" on Justia Law

The Metropolitan St. Louis Sewer District (MSD) brought claims of inverse condemnation, trespass, and negligence against the City of Bellefontaine Neighbors for damages caused to MSD sewer lines during the course of a city street improvement project. The City moved to dismiss, alleging that inverse condemnation does not apply to public property and that sovereign immunity applied and had not been waived. The trial court entered judgment in favor of the City. The Supreme Court affirmed, holding that MSD failed to state an inverse condemnation claim, and sovereign immunity barred MSD’s tort claims against the City. View "Metro. St. Louis Sewer Dist. v. City of Bellefontaine Neighbors" on Justia Law

Respondent was arrested for driving while intoxicated and agreed to take a breath test on a breath analyzer, which measured a .172-percent blood alcohol concentration (BAC). The Director of Revenue revoked Respondent’s driving privileges based on the results of the breath test. Respondent timely filed a petition for a trial de novo, arguing that her breath test results were invalid because the breath analyzer used in her case was calibrated using only one solution. The trial court agreed with Respondent and excluded the breath test results. As a result, the court concluded that the Director failed to meet the State’s burden of providing sufficient credible evidence that Respondent drove with a BAC above .08 percent. The Supreme Court affirmed, holding that the trial court (1) correctly applied the regulation in place at the time of the breath test; and (2) correctly concluded that the Director failed to lay a proper foundation for the admission of the results of Respondent’s breath test. View "Stiers v. Dir. of Revenue" on Justia Law

A police officer searched a plastic grocery bag that Defendant was holding after he was already handcuffed and seated in the police car. Inside the bag the officer discovered heroin. Defendant was charged with the class C felony of drug possession. Defendant filed a motion to suppress evidence of the heroin, arguing that neither the arrest nor the search of his plastic bag was lawful. The circuit court overruled the motion, and Defendant was convicted. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in overruling Defendant’s motion to suppress evidence of the heroin because (1) the arrest of Defendant was lawful; and (2) the search of Defendant’s bag was not a lawful search incident to arrest, but the exclusionary rule did not apply to this case. View "State v. Carrawell" on Justia Law

In 2013, Plaintiff purchased a new car from Defendant. In 2014, Plaintiff filed the underlying petition for damages, alleging that Defendant violated the Missouri Merchandising Practices Act by failing to pass title for her new vehicle. Thereafter, Defendant asked the trial court to enforce the arbitration agreement between the parties. The trial court overruled the motion to compel arbitration on the ground that the contract between the parties was void under Mo. Rev. Stat. 301.210. The Supreme Court vacated the judgment of the trial court, holding that even though the sale between Plaintiff and Defendant may be void under section 301.210, that question is for the arbitrator to determine, not the trial court. Remanded with instructions for the trial court to grant Defendant’s motion and compel arbitration. View "Ellis v. JF Enters., LLC" on Justia Law

The Director of Revenue assessed Miss Dianna’s School of Dance, Inc. $23,215 plus interest in unpaid taxes. Miss Dianna’s charged fees for dance classes that instruct participants on various styles of dance. The Commission determined that Miss Dianna’s was liable for $23,984 in unpaid tax, ruling that the dance fees were taxable under Mo. Rev. Stat. $144.020.1(2) as fees to a place of amusement, entertainment, or recreation. The Supreme Court affirmed, holding (1) because amusement or recreational activities comprise more than a de minimus portion of Miss Dianna’s business activities, it is considered a place of amusement or recreation with fees taxable under section 144.020.1(2); and (2) therefore, the Commission’s decision is authored by law and supported by competent and substantial evidence upon the record. View "Miss Dianna's Sch. of Dance, Inc., v. Dir. of Revenue" on Justia Law

The circuit court registered Kelly Blanchette and Steven Blanchette’s foreign judgment of dissolution and two subsequent judgments modifying custody visitation and support, all issued in West Virginia. Kelly had asked the Missouri county court not to register the latest West Virginia modification but to grant her proposed modification instead. Steven responded by filing a motion to dismiss for lack of jurisdiction under the Uniform Custody Jurisdiction and Enforcement Act (UCCJEA). The circuit court registered all three West Virginia judgments and dismissed Kelly’s competing motion to modify on the grounds that West Virginia retained exclusive continuing jurisdiction. The Supreme Court affirmed, holding (1) the West Virginia judgment of dissolution and both subsequent modifications were not void for lack of jurisdiction, and the Missouri court did not err in registering them in Missouri; and (2) Kelly received reasonable notice and an opportunity to be heard regarding the second custody modification sufficient to satisfy due process. View "Blanchette v. Blanchette" on Justia Law

Employee filed a claim for workers’ compensation benefits against Employer and the Second Injury Fund for an ankle injury. An Administrative Law Judge (ALJ) determined that Employee was entitled to temporary total disability (TTD) benefits but was not entitled to permanent total disability (PTD) benefits. Employee filed an application for review. The Commission modified the ALJ’s award, determining that Employee was entitled to an additional award of TTD benefits for past medical expenses. Both Employee and Employer appealed. The Supreme Court affirmed, holding that the Commission did not err in (1) denying Employee PTD benefits; and (2) modifying the ALJ’s decision and awarding Employee an additional period of TTD benefits. View "Greer v. Sysco Food Servs." on Justia Law