Justia Missouri Supreme Court Opinion Summaries

Petitioner was convicted of two counts of first-degree murder for the murders to two sisters. Petitioner was sentenced to death for the murders. Petitioner filed a petition for a writ of habeas corpus in the Supreme Court, claiming that newly discovered evidence showed that the State violated Brady v. Maryland by withholding material evidence and that the Brady violation was prejudicial. The Supreme Court appointed a special master to take evidence and issue findings of fact and conclusions of law as to Petitioner’s allegation. The master eventually issued a report finding that the State had violated Brady by failing to produce evidence favorable to Petitioner and that the State’s failure to disclose this evidence was prejudicial to Petitioner. The Supreme Court adopted the master’s recommendation and vacated Petitioner’s convictions and sentences for first-degree murder, holding that substantial evidence supported the master’s findings that the State deliberately violated Brady and that the suppressed evidence, along with the totality of other evidence, showed cause and prejudice sufficient to undermine confidence in the outcome of the trial. View "State ex rel. Clemons v. Larkins" on Justia Law

Gerald Geier, an accountant, was the treasurer of Stop Now!, a Missouri political action committee (PAC). Geier was required to register the PAC with the Missouri Ethics Commission (MEC). Stop Now! became inactive after 2003, and the PAC’s bank account closed in 2006. When Stop Now! failed to file disclosure reports for the first three quarters of 2011, the MEC opened an investigation. The MEC subsequently filed a complaint against Geier and Stop Now!, alleging that they violated Mo. Rev. Stat. 13.046.1, 130.021.4(1) and 130.021.7 by failing to timely file disclosure reports and failing to notify the MEC of the closure of the PAC’s bank account. After a hearing, the MEC found probable cause that Geier and Stop Now! knowingly violated the applicable statutes. Geier sought judicial review, challenging, inter alia, the constitutional validity of the reporting statutes. The circuit court granted summary judgment in favor of the MEC. The Supreme Court affirmed, holding (1) the reporting statutes are constitutional as applied; (2) Geier’s challenges to the facial validity of the reporting statutes are not ripe; (3) section 105.961.3, the statute that requires the MEC’s hearings be closed to the public, does not violate the First or Sixth Amendments; and (4) the MEC had authority to investigate Geier. View "Geier v. Missouri Ethics Comm’n" on Justia Law

Appellant filed suit against Robinwood West Community Improvement District, alleging that Robinwood violated the Sunshine Law by not disclosing various public records, including those relating to Robinwood’s settlement of a personal injury lawsuit. Appellant also requested attorney fees and a civil penalty, asserting that Robinwood knowingly and purposely violated the Sunshine Law. The trial court entered judgment in favor of Appellant and ordered Robinwood to disclose the documents regarding the settlement agreement and the sums of money expended on the lawsuit. The court, however, denied Appellant’s request for attorney fees and a civil penalty. The Supreme Court reversed in part, holding that the trial court erred in concluding, as a matter of law, that Robinwood could not have knowingly or purposely violated the Sunshine Law. Remanded. View "Strake v. Robinwood W. Cmty. Improvement Dist." on Justia Law

Appellant, a juvenile, was convicted of first-degree attempted rape. The juvenile court ordered that Appellant register on the juvenile sex offender registry. Appellant appealed, arguing that ordering him to register as a sexual offender for his lifetime, pursuant to Mo. Rev. Stat. 211.425 and 589.400.1(6), violated his constitutional rights. The Supreme Court dismissed Appellant’s claims without prejudice, holding that Appellant’s challenge to the enforcement of section 589.400.1(6), which was not made part of the judgment against Appellant, was not ripe for review, and the lack of justiciability precluded relief in this action. View "S.C. v. Juvenile Officer" on Justia Law

Father was charged with criminal nonsupport in violation of Mo. Rev. Stat. 568.040. Father filed a motion to dismiss the information and to declare section 568.040.1 unconstitutional as a violation of his due process rights under the United States and Missouri constitutions. The trial court granted the motion and dismissed the information, concluding that the 2011 amendment to the statute, which removed the phrase “without good cause” as an element of the offense, and instead expressed it as an affirmative defense, impermissibly shifted the burden of proof to the defendant on an element of the crime. The Supreme Court reversed, holding that the statute is constitutional because due process allows a defendant to bear the burden of pleading and proving the affirmative defense of inability to provide support for good cause. View "State v. Meacham" on Justia Law

Plaintiffs filed a wrongful death action alleging that the negligent chiropractic services of Defendants caused the death of their relative. Plaintiffs filed an affidavit stating that they obtained the written opinion of a qualified health care provider in support of their claims as required by Mo. Rev. Stat. 538.225. Plaintiffs later voluntarily dismissed that action. Thereafter, Plaintiffs refiled an identical petition in the same court but did not attach the affidavit to their new petition. The trial court dismissed the action without prejudice under action 538.225 because Plaintiffs failed to file the affidavit within 180 days of filing the second action. The Supreme Court affirmed, holding that the trial court properly sustained Defendants’ motion to dismiss without prejudice for Plaintiffs’ failure to comply with the requirements of section 538.225. View "Lang v. Goldsworthy" on Justia Law

New Garden Restaurant, Inc. received “estimated audit assessments” from the Department of Revenue notifying New Garden that it owed $43,738 in unpaid sales tax. New Garden claimed it never received final assessment notices sent by the Department of Revenue. New Garden appealed the Director of Revenue’s tax assessments against it more than two weeks past the deadline. The Administrative Hearing Commission entered a summary decision dismissing New Garden’s appeal, ruling that it had no authority to hear New Garden’s appeal because the appeal was not filed within the time limitation for doing so. The Supreme Court affirmed, holding (1) under the circumstances of this case, there was no due process violation; (2) equitable estoppel does not excuse New Garden’s late filing; and (3) the Commission did not err in its findings. View "New Garden Restaurant, Inc. v. Dir. of Revenue" on Justia Law

Plaintiff was sixty-one years old when his employment with the Kansas City Chiefs was terminated. Plaintiff was replaced by a younger worker. Plaintiff filed a petition in the circuit court alleging a single act of age discrimination on the day of his termination. In pretrial proceedings, the trial court denied Plaintiff’s request to have testimony presented to the jury from numerous nonparty former employees over age forty who were either fired or pressured to resign and their job duties were assumed by younger replacements. The jury ultimately returned a verdict in favor of the Chiefs. The Supreme Court vacated the judgment, holding that the trial court (1) misapplied the legal standard for admission of evidence by so-called “me too” witnesses and abused its discretion in excluding “me too” evidence offered by the former employees; and (2) erred in excluding evidence concerning a discriminatory age-related statement allegedly made by a Chiefs executive and in quashing a deposition order issued to the Chiefs’ chairman and chief executive officer. Remanded. View "Cox v. Kansas City Chiefs Football Club, Inc." on Justia Law

Appellant, who was incarcerated, sought a dissolution of his marriage to his wife. The circuit court entered an order dismissing Appellant’s petition. Appellant appealed, challenging the constitutional validity of the application of Mo. Rev. Stat. 544.275 and Mo. Rev. Stat. 491.230 to him, asserting that these sections violated his right to due process because they denied him the right to be present in court to litigate his civil action and further denied him any reasonable alternatives to appearance in person. The Supreme Court transferred the appeal to the court of appeals, holding that Appellant failed to raise a real and substantial constitutional challenge to the validity of either statute so as to invoke the Court’s exclusive appellate jurisdiction. View "McNeal v. McNeal-Sydnor" on Justia Law

In 2013, the State charged Bob Beisly with the 2009 death of Belinda Beisley. Wilma Jean Irwin subsequently filed a wrongful death action against Beisly. Beisly moved to dismiss Irwin’s action, arguing that her claim was time-barred by Mo. Rev. Stat. 537.100, the wrongful death statute of limitations. Irwin opposed the motion, arguing that Beisly should be estopped from relying on the statute of limitations as a defense due to his fraudulent concealment of his wrongdoing. The circuit court overruled Beisly’s motion, stating that allowing Beisly to escape civil liability on the basis of the statute of limitations was “shocking to the conscience.” Beisly sought a writ of prohibition in the court of appeals. After opinion by that court, the Supreme Court granted transfer. The Supreme Court quashed the preliminary order in prohibition, holding that the doctrine of equitable estoppel foreclosed Beisly from relying on the statute of limitations as an affirmative defense due to the fraudulent concealment of his wrongdoing. View "State ex rel. Beisly v. Hon. Perigo" on Justia Law