Justia Missouri Supreme Court Opinion Summaries

After the General Assembly enacted HB 1171, which amended Mo. Rev. Stat. 67.320 to permit any first-class county within a certain population range to establish a county municipal court division, the Franklin County Commission entered a county order establishing a municipal court division pursuant to the amended section 67.320. Taxpayers of Franklin County sued the members of the Commission, alleging that HB 1171’s enactment violated constitutional prohibitions against multiple subjects and change of original purpose and that the Commission’s order was void. On remand, the trial court concluded that HB 1171’s enactment was constitutional. While Taxpayers’ appeal was pending, the General Assembly passed SB 621, which repealed and reenacted section 67.320, including the language regarding establishment of a municipal court division. The Supreme Court dismissed the appeal as moot, as Taxpayers’ appeal no longer represented an actual controversy. View "LeBeau v. Comm’rs of Franklin County" on Justia Law

After a jury trial, Cecil Clayton was found guilty of first-degree murder and sentenced to death. After unsuccessfully pursuing an appeal and post-conviction relief, Clayton filed a federal petition for a writ of habeas corpus, which the federal district court denied. The U.S. Supreme court affirmed that decision. On February 6, 2015, this Supreme Court scheduled the execution of Clayton. Clayton filed a petition for writ of habeas corpus claiming he was not competent to be executed under Ford v. Wainwright, Panetti v. Quarterman, and Mo. Rev. Stat. 552.060.1. The Supreme Court denied Clayton’s petition for writ of habeas corpus and overruled as moot Clayton’s accompanying motion for a stay of execution, holding (1) Clayton was competent to be executed under Ford and Panetti and met the standard for competence in section 552.060.1; (2) Mo. Rev. Stat. 552.060.2 is not unconstitutional; and (3) Clayton is not intellectually disabled under Missouri law and therefore not categorically excluded from eligibility for the death penalty. View "State ex rel. Clayton v. Griffith" on Justia Law

Defendant was charged with murder in the first degree, assault in the first degree, and two counts of armed criminal action. On the day of trial, after the trial court denied the state’s request to reconsider granting a continuance, the state dismissed the case nolle prosequi. Later that day, the state filed a new complaint with the same charges against Defendant. Defendant filed a motion to dismiss based on a violation of his right to a speedy trial. The trial court overruled the motion to dismiss. After a trial, Defendant was convicted of the charges. The Supreme Court affirmed, holding that the trial court did not err in (1) not designating the state’s nolle prosequi as a dismissal with prejudice because the court did not have authority to do so; and (2) overruling Defendant’s motion to dismiss, as no prejudice resulted from the delay, and therefore, Defendant’s right to a speedy trial was not violated. View "State v. Sisco" on Justia Law

Client retained Attorney to handle various legal claims pertaining to the management of a trust. Attorney later came to represent Client and his wife in matters of their own estate planning and administration. Upon Attorney’s advice, Client made loans to both the Attorney’s law firm and to a business from which Attorney received a commission for the referral. Attorney did not make a written disclosure or advise Client to seek independent legal advice regarding these transactions. The loans were never repaid. Client filed a malpractice action against Attorney for breach of fiduciary duty. Judgment was entered in favor of Client. Client subsequently filed an equitable garnishment action against Attorney’s malpractice insurer (Insurer) seeking to recover the judgment under the policy. The trial court granted summary judgment for Insurer, concluding that coverage was excluded under the policy’s “legal representative of investors” exclusionary clause. The Supreme Court affirmed, holding that, under the facts of this case, the trial court was correct in holding that the exclusionary clause unambiguously excluded coverage for Attorney’s injurious acts and omissions. View "Taylor v. Bar Plan Mut. Ins. Co." on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder, first-degree assault, and two counts of armed criminal action. Defendant moved for a judgment of acquittal notwithstanding the jury’s verdict, asserting that convictions for first-degree murder and armed criminal action in connection with the murder, first-degree assault, and armed criminal action in connection with the assault violated double jeopardy. The circuit court partially granted this motion and acquitted Defendant of first-degree assault and the related armed criminal action conviction. Defendant appealed, and the State cross-appealed. The Supreme Court (1) reversed the circuit court’s judgment with respect to the assault and related armed criminal action and remanded for sentencing on the jury’s verdicts on those offenses, holding (a) the circuit court’s failure to accurately record that Defendant’s convictions resulted from trial rather than a plea of guilty was a clerical mistake that should be corrected, and (b) the circuit court erred in ruling that the murder and assault convictions violated double jeopardy; and (2) affirmed the judgment in all other respects. View "State v. Smith" on Justia Law

Issiah Andra, a Missouri resident, filed a petition against Texas-based Left Gate Property Holding, Inc. after Andra purchased on eBay a vehicle from Left Gate that did not meet Andra’s expectations. The circuit court dismissed the petition for lack of personal jurisdiction over Left Gate. Andra appealed, arguing that Left Gate had sufficient minimum contacts with Missouri to be subject to personal jurisdiction in Missouri in accordance with the due process clause of the Fourteenth Amendment. The Supreme Court reversed, holding that Left Gate’s conduct in Missouri fell within Missouri’s long-arm statute, and Left Gate had sufficient minimum contacts with Missouri to satisfy the due process clause. View "Andra v. Left Gate Prop. Holding, Inc." on Justia Law

Five Delta Alpha, LLC (FDA) purchased an aircraft and immediately leased it to JetSelect, LLC. After paying Missouri use tax under protest, FDA filed a use tax refund claim with the Director of Revenue, asserting that the purchase of the aircraft was eligible for exemption pursuant to Mo. Rev. Stat. 144.030.2(20) because the aircraft was leased to JetSelect as a common carrier providing air carrier service to the general public. The Director denied the claim. On appeal, the Administrative Hearing Commission (AHC) concluded that JetSelect was a common carrier but determined that FDA was not entitled to the refund because its lease was not a “sale” for purposes of the resale exemption. The Supreme Court reversed, holding that FDA showed clear and unequivocal proof that it qualified for the exemption because the lease to JetSelect constituted a sale for sales tax purposes. View "Five Delta Alpha, LLC v. Dir. of Revenue" on Justia Law

When two of Price Chopper’s employees saw Deborah Barkley head for the store’s exit without paying for certain items, they confiscated the items and detained her at the store’s security office on suspicion of shoplifting. Approximately forty-five minutes after Barkley was first detained, the police arrested her and escorted her from the store. Barkley was charged with shoplifting but was later acquitted of this charge. Barkley sued Price Chopper, alleging various torts arising out of her detention. At the close of the evidence, Barkley abandoned all of her claims except false imprisonment and battery. The jury found for Price Chopper on both counts. Barkley appealed, arguing that the merchant’s privilege extends to claims of battery, and the privilege ends when the merchant’s property is recovered. The Supreme Court affirmed, holding that a merchant is privileged to detain a person in a reasonable manner and for a reasonable time if the merchant has probable cause to believe that person is shoplifting, and the merchant may continue the detention after the property is recovered to determine whether the person was actually shoplifting and to summon the police and instigate criminal proceedings. View "Barkley v. McKeever Enters., Inc." on Justia Law

Custom Built, a personal training company, paid Powerhouse Gym of Joplin (Powerhouse), a fitness facility, rental fees covering the lease of office space and the opportunity to market and sell personal training services to Powerhouse members. The Department of Revenue (DOR) issued an assessment against Powerhouse for unpaid sales tax on the rental fees. Powerhouse challenged the assessment, and the Administrative Hearing Commission (AHC) determined that Powerhouse did not owe sales tax on the rental fees collected from Custom Built. DOR appealed, contending that the rental fees were subject to sales tax as a fee paid to a place of recreation under Mo. Rev. Stat. 144.020.1(2). The Supreme Court affirmed the AHC’s decision, holding that Powerhouse was not liable for sales tax on the monthly rental fees because Powerhouse did not render a taxable service to Custom Built. View "Tatson, LLC v. Dir. of Revenue" on Justia Law

After a jury trial, Defendant was found guilty of one count of first-degree statutory sodomy. Defendant appealed, arguing that the trial court erred by (1) denying his motion to disqualify the entire Newton County Prosecuting Attorney’s Office (NCPAO) due to a conflict of interest, and (2) entering a written judgment reflecting convictions of two counts of first-degree statutory sodomy when, in fact, Defendant was convicted of only one count of that offense. The Supreme Court affirmed the judgment as to one count of first-degree statutory sodomy and vacated the judgment as to the second count of first-degree statutory sodomy, holding (1) the trial court did not abuse its discretion in overruling Defendant’s motion to disqualify the entire NCPAO; and (2) because the written judgment erroneously stated that Defendant was found guilty on two counts of first-degree statutory sodomy, the written judgment must be corrected to reflect what actually occurred. View "State v. Lemasters" on Justia Law