Justia Missouri Supreme Court Opinion Summaries

Evolution Development LLC purchased land to create the Arbors at Sugar Creek through loans provided by Jefferson Bank & Trust Company. Evolution recorded an “Indenture” to run with the land. Evolution subsequently declared bankruptcy, and Jefferson Bank foreclosed. Jefferson Bank partnered with McKelvey Homes, LLC to finish building homes on the remaining lots. The existing homeowners deemed the building plans in violation of the Indenture, which led to the current dispute. The homeowners filed suit against McKelvey and Jefferson Bank seeking declaratory and injunctive relief and alleging claims of damages. Jefferson Bank filed a three-count counterclaim petition seeking declaratory relief and damages against the homeowners. The circuit court (1) granted summary judgment in favor of Plaintiffs on Counts II and III of Jefferson Bank’s counterclaim petition; (2) granted summary judgment in favor of Jefferson Bank and McKelvey on Counts II-V of Plaintiffs’ petition; (3) granted declaratory relief in favor of Jefferson Bank and McKelvey; and (4) sustained Jefferson Bank’s motion for reimbursement. The Supreme Court (1) reversed in part, holding that the circuit court erred in sustaining Jefferson Bank’s motion for reimbursement; and (2) affirmed in all other respects, holding that summary judgment was properly entered and that the circuit court did not err in granting declaratory relief. View "Arbors at Sugar Creek Homeowners Ass’n v. Jefferson Bank & Trust Co., Inc." on Justia Law

Charles and Deborah Bate were both seriously injured in a head-on vehicle collision. After obtaining a judgment against the driver of the opposing vehicle the Bates sued Greenwich Insurance Company seeking underinsured motorist coverage under a policy allegedly issued to Charles Bate’s employer by Greenwich. Greenwich did not answer the petition, and the Bates obtained a default judgment in the amount of $3 million. More than two years later, Greenwich filed an amended motion to set aside the default judgment as void, arguing that service of process was invalid. The trial court set aside the default judgment as void, stating that there was no valid service of process. The Supreme Court reversed, holding that the Bates properly effected service of process under Mo. Rev. Stat. 375.906 and complied with all service requirements of that statute. View "Bate v. Greenwich Ins. Co." on Justia Law

Airport Tech Partners, LLP and Stentor Company, LLC (collectively, Airport Tech) brought a declaratory judgment action against the State, arguing that section 137.115.1 violates the uniformity clause of the Missouri Constitution. Airport Tech claimed it had taxpayer standing to challenge the statute because a lower assessment of airport property owned by Kansas City likely would result in a high tax burden for Airport Tech. The trial court concluded that Airport Tech lacked standing to seek a declaratory judgment because it presented only speculation that the statute relied on affected the level of the airport property’s assessment. The Supreme Court affirmed, holding that the trial court correctly concluded that Airport Tech simply sought to attack the assessment of another’s property as a way to lower its own taxes. View "Airport Tech Partners, LLP v. State" on Justia Law

After a jury trial, Defendant was convicted of second-degree murder and second-degree arson. The trial court sentenced Defendant to life imprisonment for the murder. Before the jury began deliberating, the trial court excused Juror 14, who was an alternate juror. After the jury had begun deliberating, Juror 12 was excused due to health concerns, and Juror 14 was substituted for Juror 12. Defendant appealed, arguing that the trial court improperly substituted Juror 14 after deliberations had begun. The Supreme Court reversed, holding that the trial court erred by substituting a discharged alternate juror after the jury had retired to consider its verdict, and the error deprived Defendant of his statutory right to have the same twelve jurors deliberate and decide his case. View "State v. Amick" on Justia Law

Plaintiff brought this action against Union Electric Company (UE) for wrongful death after her two children drowned in the Lake of the Ozarks, an impoundment created by Bagnell Dam. Both the Lake and the dam are owned by UE. Plaintiff alleged that her children encountered stray electric current that caused the children’s death from drowning, electrocution, or both. The trial court dismissed the petition, concluding that UE was immune from Plaintiff’s claims under the Recreational Use Act (RUA). The Supreme Court affirmed, holding that UE was entitled to immunity under the RUA, and therefore, the trial court properly dismissed Plaintiff’s petition. View "Anderson v. Union Elec. Co." on Justia Law

Liberty Energy (Midstates) Corp. (Liberty), a public utility and a gas corporation, requested an increase to its Infrastructure System Replacement Surcharge (ISRS). After an evidentiary hearing, the Missouri Public Service Commission (PSC) approved the ISRS increase for Liberty. Accordingly, Liberty filed new ISRS tariffs in compliance with the PSC’s order, and the PSC approved the tariffs. The Office of Public Counsel, which is appointed by the director of the department of economic development and may represent the public interest in appeals from the PSC’s orders, appealed. The Supreme Court reversed, holding that the PSC failed to follow the plain language of its statutory mandates, and therefore, its order was unlawful. Remanded. View "Missouri Pub. Serv. Comm’n v. Office of Pub. Counsel" on Justia Law

After a jury-waived trial, Defendant was convicted of second-degree robbery. Defendant was sentenced as a persistent offender to ten years’ imprisonment. Defendant appealed, arguing that there was insufficient evidence to support his conviction because he did not forcibly steal the money through the use or threatened use of force. The Supreme Court affirmed, holding that there was sufficient evidence supporting the trial court’s finding that Defendant committed the crime of second-degree robbery because he forcibly stole the money by means of an actual or attempted threat. View "State v. Coleman" on Justia Law

In 2003, Appellant was convicted of two counts of first degree murder and sentenced to death. In 2015, Appellant filed a petition for a writ of habeas corpus, claiming that he should not be executed because he was severely mentally ill at the time he committed the crimes. The Supreme Court denied the habeas petition, holding that Appellant failed to raise any legally cognizable claim for habeas relief related to his claim that he was mentally ill at the time of the murders where (1) Appellant failed to raise his claim at trial, on appeal, or during post-conviction relief proceedings; and (2) Appellant did not make a threshold showing that his current mental condition makes him incompetent to be executed. View "State ex rel. Strong v. Griffith" on Justia Law

Plaintiff purchased a manufactured home from Defendant. The contract between Plaintiff and Defendant included an arbitration clause. Plaintiff later sued Defendant alleging fraud, negligence, breach of contract, and negligent misrepresentation. Defendant filed a motion to dismiss or to stay the court action and to compel arbitration. Plaintiff opposed arbitration, arguing that the arbitration agreement lacked mutuality and was unconscionable on multiple grounds. The trial court overruled Defendant’s motion. The Supreme Court reversed, holding (1) the agreement’s “anti-waiver clause” was unconscionable and invalid, but the anti-waiver provision could be severed; (2) Plaintiff’s remaining objections did not render the contract as a whole unconscionable; and (3) absent the anti-waiver clause, the contract was not unconscionable. View "Eaton v. CMH Homes, Inc." on Justia Law

Relator pleaded guilty to one count of driving while intoxicated as a chronic offender and was sentenced to five years imprisonment and participation in a long-term substance abuse treatment program. After successfully completing the treatment program, the circuit court directed that Relator be released on probation on June 8, 2015. Relator filed this petition for writ of mandamus arguing that he was entitled to immediate release on probation pursuant to Mo. Rev. Stat. 217.362.3 because he successfully completed the program. The Supreme Court denied the petition, holding that Relator’s proposed June 8, 2015 release date satisfied the requirement that he serve at least two years of imprisonment as required by statute while meeting all requirements imposed by the plain language of section 217.362.3. View "State ex rel. Hodges v. Hon. Asel" on Justia Law