Justia Missouri Supreme Court Opinion Summaries

The Supreme Court dismissed this appeal brought by the State of an order and judgment dismissing with prejudice criminal charges against Defendant, holding that there was no final, appealable judgment, and therefore, the State lacked statutory authority to appeal pursuant to Mo. Rev. Stat. 547.200.Defendant, who was charged with second-degree murder, first-degree robbery, and armed criminal action, filed a motion to dismiss the indictment. The circuit court sustained the motion in part and dismissed the murder and robbery charges with prejudice, concluding that the Double Jeopardy Clause precluded those charges. The State appealed. The Supreme Court dismissed the appeal, holding that this was an improper appeal. View "State v. Harris" on Justia Law

The Supreme Court granted a writ of prohibition barring the circuit court from taking any further action in Petitioner's criminal case other than dismissing the pending charges against him, holding that the Interstate Agreement on Detainers (IAD) mandated dismissal of Petitioner's case.As a basis for the writ, Petitioner claimed that the circuit court violated the IAD by continuing his criminal case and failing to conduct a trial within 180 days of his request to dispose of his pending charges of rape, sodomy, and sexual abuse. The Supreme Court agreed and granted the writ, holding (1) the IAD applied to the disposition of the state charges pending against Petitioner resulting in a detainer being lodged with the federal penitentiary where he was serving a federal sentence; (2) the State waived any post hoc objection as to the sufficiency of Petitioner's request to dispose of his pending charges; (3) good cause did not exist under the IAD warranting continuing Petitioner's trial; and (4) Petitioner's actions did not waive, toll or otherwise justify extending the timeline mandated by the IAD. View "State ex rel. Wishom v. Honorable Bryant" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Caitlyn Williams and Tamara LaRue (together, Parents) of failing to cause their children to attend school on a regular basis in violation of Missouri's compulsory attendance law, holding that Mo. Rev. Stat. 167.031.1 was not unconstitutionally vague as applied in this case.On appeal, Parents argued, among other things, that the State failed to prove beyond a reasonable doubt both that their conduct was a purposeful or knowing violation of Mo. Rev. Stat. 167.031.1 and that the children's attendance was not sufficiently "regular" to constitute a statutory violation. The Supreme Court affirmed, holding (1) section 167.031.1 was not unconstitutionally vague as applied to the facts of this case; and (2) there sufficient evidence to find that Parents knowingly failed to cause their children to attend school on a regular basis after their children were enrolled. View "State v. LaRue" on Justia Law

In this declaratory judgment action, the Supreme Court vacated the judgment of the circuit court overruling the motion to intervene as a matter of right filed by St. Louis and Jackson counties (the Counties), holding that the circuit court erred in overruling the Counties' motion to intervene as a matter of right.Plaintiffs brought this suit against the Department of Health and Senior Services. The circuit court ultimately declared that 19 C.S.R. 20-20.050(3) was constitutionally invalid. Several entities filed motions to intervene, including the Counties. The circuit court overruled all motions to intervene. The Supreme Court vacated the order below, holding that the circuit court erred in denying intervention where the motions were timely filed, the counties had an interest in the subject matter of the action, disposition of the action would impede their interests, and the existing parties no longer adequately represented their interest. View "Robinson v. Mo. Dep't of Health & Senior Services" on Justia Law

The Supreme Court made permanent a preliminary writ it issued granting Monsanto Company's petition for a writ of prohibition or mandamus requiring the St. Louis circuit court to transfer venue of five of the six plaintiffs' claims, holding that Missouri law compelled this result.Plaintiffs brought this action claiming that they were injured as a result of exposure to a herbicide manufactured by Monsanto Company and seeking monetary damages. Monsanto filed a motion to transfer venue as to five of the six plaintiffs in this case to St. Louis County but failed to file a motion to transfer in the six plaintiff's case The circuit court subsequently consolidated Plaintiffs' individual claims. Monsanto filed a motion to reconsider, arguing that venue was inappropriate in St. Louis Valley. The circuit court overruled the motion, after which Monsanto sought relief by way of mandamus or prohibition. The Supreme Court granted relief, holding that Mo. Rev. Stat. 508.010.5(1) mandated that venue shall be where Monsanto's registered agent was located as of filing - St. Louis County. View "State ex rel. Monsanto Co. v. Honorable Mullen" on Justia Law

The Supreme Court reversed the order of the Public Service Commission granting the joint application of Missouri-American Water Company and DCM Land LLC for variances from Missouri-American Water Company's tariff absent explicit language in the traffic allowing for variances, holding that the Commission did not have the authority to grant the variance.Water Company and DCM sought three variances from the tariff, which governed the funding of water main extensions. Specifically, the parties sought variances from the language of Rules 23.A.39 and 23.C.6 in the tariff. The Commission granted the requested variances after finding that good cause existed. The Supreme Court reversed, holding that because there was no language in the rules allowing for a variance, the Commission lacked the authority to grant such variances as those sought in this case. View "In re Joint Application of Missouri-American Water Co. & DCM Land, LLC" on Justia Law

The Supreme Court affirmed the judgment of the circuit court making permanent a writ of mandamus ordering Attorney General Andrew Bailey to approve fiscal note summaries for eleven proposed initiative petitions Dr. Anna Fitz-James had filed with Secretary of State John Ashcroft and to forward notice of that approval to State Auditor Scott Fitzpatrick, holding that there was no error.Specifically, the Supreme Court held (1) nothing in Mo. Rev. Stat. 116.175 gives the Attorney General authority to question the Auditor's assessment of the fiscal impact of a proposed petition, and the Attorney General's authority extends only to reviewing the "legal content and form" of the fiscal notes and summaries prepared by the Auditor; (2) the circuit court properly found there was no defect in the legal form and content of the fiscal note summaries prepared by the Auditor concerning the proposed initiative petitions; and (3) therefore, the Attorney General's refusal to perform the duty of approving those summaries could not be justified. View "State ex rel. Fitz-James v. Bailey" on Justia Law

The Supreme Court reversed the decision of the Missouri Mining Commission awarding attorney fees and expenses in favor of Fowler Land Company and the Margaret Leist Revocable Trust (collectively, Landowners) after Landowners prevailed in litigation concerning the creation of water impoundments on their property, holding that the Commission erred in awarding fees and expenses.Alternative Fuels, Inc. (AFI) leased land from Landowners, who consented to AFI's creation of water impoundments on their property, but AFI constructed additional impoundments without consent. Missouri Department of Natural Resources (DNR) initiated enforcement actions against AFI, after which AFI received approval for a permit revision. The Commission upheld the approval. The circuit court reversed. On remand, the Commission denied the permit revision application. Thereafter, Landowners filed an application for attorney fees and expenses arguing that they were the prevailing party and were entitled to attorney fees. The Commission granted the application. The Supreme Court reversed, holding that Landowners' fee application was untimely, and therefore, the Commission erred in awarding Landowners attorney fees and expenses. View "State ex rel. Dep't of Natural Resources v. Fowler Land Co." on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing the underlying wrongful death lawsuit, holding that the allegations of the petition established that Crystal May was entitled to official immunity, as a matter of law, and therefore, the petition failed to state a claim upon which relief could be granted.Plaintiff brought a wrongful death suit against May, alleging that May, a children's division caseworker, owed M.S., a toddler who died from a fentanyl overdose, a ministerial duty to make a SAFE CARE provider referral and that the failure to make such a referral under after M.S. died resulted in M.S.'s death. The circuit court dismissed the petition, finding that May was entitled to official immunity and that the complaint failed to allege sufficient facts establishing that May caused M.S.'s death. The Supreme Court affirmed, holding that the allegations of Plaintiff's petition established that May was entitled to official immunity as a matter of law. The Supreme Court affirmed, holding that the allegations in the petition established that May was entitled to official immunity as a matter of law. View "Forester v. May" on Justia Law

The Supreme Court dismissed Defendant's appeal of the circuit court's final judgment in this criminal case, holding that Defendant's appeal was untimely.After a jury trial, Defendant was found guilty of financial exploitation of an elderly person by undue influence. The circuit court sentenced her to ten years in prison and ordered her to pay restitution as a condition of parole. The circuit court dismissed Defendant's appeal. Thereafter, the circuit court set the amount of restitution and purported to resentence her to fifteen years in prison plus $26,118.51 in restitution. The Supreme Court dismissed Defendant's appeal, holding that Defendant's notice of appeal was untimely. However, the Supreme Court remanded the case with directions for the circuit court to vacate the second judgment and sentence, holding that when the circuit court orally sentenced Defendant to ten years in prison, it exhausted its jurisdiction to withdraw Defendant's sentence, resentence her, or add restitution to the judgment. View "State v. Forbes" on Justia Law