Justia Missouri Supreme Court Opinion Summaries

In 2008, the General Assembly passed a senate bill that was codified as Mo. Rev. Stat. 393.1050, a statute exempting electric utilities that met a certain renewable energy target on a certain date from any solar energy requirements. A ballot initiative (“Proposition C”) was subsequently passed that imposed solar energy requirements on all electric utilities. Earth Island Institute, doing business as Renew Missouri, and additional parties filed a complaint with the Public Service Commission claiming that section 393.1050 was invalidated by the passage of Proposition C. The Commission determined that Proposition C did not impliedly repeal section 393.1050 because the two laws could be harmonized. The Supreme Court reversed, holding that section 393.1050 was impliedly repealed by the adoption of Proposition C because section 393.1050 in its entirety was in conflict with Proposition C. View "Earth Island Inst. v. Union Elec. Co." on Justia Law

This case centered on a petition to dissolve a same-sex marriage. The circuit court, sua sponte, dismissed the action on grounds that it lacked subject matter jurisdiction and constitutional and statutory authority to dissolve a same-sex marriage due to the state constitutional and statutory bans on same-sex marriage. The Supreme Court reversed, holding that the circuit court had subject matter jurisdiction because the plain language of Mo. Const. art. V, 14 provides that Missouri circuit courts have jurisdiction over all civil cases and matters, and a petition for dissolution of marriage is a civil case or matter falling within the jurisdiction of the circuit court. View "In re Marriage of M.S." on Justia Law

Eric Williams, the second cousin of Betty Reynolds, sued attorney Kenneth Nelson and his wife, Sandra Nelson. Kenneth had been retained by Reynolds to advise her in achieving her estate planning objectives. Williams claimed that the Nelsons violated their fiduciary duties to Reynolds by unduly influencing Reynolds to give Sandra joint ownership of - or to designate Sandra as the “payable on death” (POD) beneficiary on - most of Reynolds’ assets. The trial court granted summary judgment for the Nelsons, concluding that Williams lacked standing to bring these claims because he had no right to any of the assets at issue and therefore suffered no harm from the Nelsons’ alleged undue influence over Reynolds . The Supreme Court (1) affirmed the trial court’s dismissal of Williams’ claims with respect to claims relating to certain accounts; but (2) vacated the dismissal of Williams’ claims pertaining to the accounts for which there was no valid joint ownership or POD designation in effect at the time the Nelsons allegedly unduly influenced Reynolds to give Sandra her interests, holding that Williams had standing to challenge Sandra’s ownership of, and the Nelsons’ conduct, concerning these accounts. View "Williams v. Hubbard" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder, armed criminal action, first-degree burglary, and unlawful possession of a firearm by a felon. Defendant was sentenced to death for the murder charge. The Supreme Court affirmed, holding (1) even assuming the police violated Defendant’s Fourth Amendment rights, evidence seized from Defendant’s person and car was admissible because Defendant’s flight and the nature of the alleged violation purged the evidence of any taint of an illegal stop; (2) there was sufficient probable cause to support a search warrant for Defendant’s apartment; (3) evidence of other weapons and ammunition unrelated to the crime was relevant and therefore admissible; (4) the victim’s statements on an application for a protective order and to her landlord about Defendant were admissible under the forfeiture by wrongdoing doctrine; (5) a note found in Defendant’s car was authenticated by circumstantial evidence; (6) there was sufficient evidence to support Defendant’s conviction for first-degree burglary; and (7) Defendant’s sentence was proportional. View "State v. Hosier" on Justia Law

In 2000, Plaintiff purchased a lot in a subdivision being developed by Markirk Construction, Inc., of which Kirk Jones was president. The next year, Plaintiff completed construction of a home on the lot. In 2009, Plaintiff filed suit against Defendants, alleging fraudulent misrepresentation in connection with the negotiation and sale of the lot. The jury found in favor of Jones. On appeal, Plaintiff argued that the trial court erred in instructing the jury that it had to find Jones knew that the alleged misrepresentations were false when he made them. The Supreme Court affirmed, holding that the trial court properly instructed the jury that Defendant’s alleged representations concerned future events, and therefore, in order for Plaintiff to recover, Jones must have made these representations with knowledge when they were made that the representations were false. View "Stevens v. Markirk Construction, Inc." on Justia Law

Barbara Hiles purchased two American Family Mutual Insurance policies on two vehicles she owned, a Nissan and a Ford. While driving her Nissan, Hiles was involved in a motor vehicle accident that injured Adam Dutton. Dutton sued Hiles and made a settlement demand of $50,000, which was the combined policy limits of the Nissan policy added to what Dutton claimed were the minimum policy limits required under the Motor Vehicle Financial Responsibility Law (MVFRL) for the Ford policy. Dutton, Hiles, and American Family entered into a settlement under which Dutton received $25,000 under the Nissan policy and was assigned Hiles’ right to sue American Family for issues arising from the Ford policy. Dutton then filed a declaratory judgment action against American Family seeking a determination whether the Ford policy provided $25,000 additional coverage for his injuries. The trial court entered judgment for American Family. The Supreme Court affirmed, holding that the Ford policy’s plain language did not require American Family to provide coverage for the accident, and the MVFRL did not require American Family to pay the statutory minimum of $25,000 of liability coverage on the Ford policy because the Nissan was owned by the insured but not designated in the Ford policy. View "Dutton vs. American Family Mut. Ins. Co." on Justia Law

The juvenile officer for the 10th Judicial Circuit filed an Emergency Petition for Protective Custody in the juvenile division of the circuit court after Mother denied the existence of her five-year-old son, JC. At an initial hearing, Mother appeared without JC and repeatedly testified under oath that JC did not exist. Mother subsequently surrendered JC to the juvenile officer and conceded that JC was her child. Thereafter, Mother was charged with perjury based on the false testimony she gave at the protective custody hearing. Mother moved to suppress her testimony on the ground that the conduct of the protective custody hearing violated her right to counsel and her privilege against self-incrimination. The motion was overruled, and Mother was found guilty of one count of perjury. The Supreme Court affirmed, holding (1) the trial court did not err in overruling Mother’s motion to suppress; and (2) the evidence was sufficient to prove that Mother committed perjury. View "State v. Churchill" on Justia Law

After Mother applied for child support enforcement services, the Family Support Division (FSD) issued an administrative child support order stating the proposed rights and obligations of Mother and Father. Mother disagreed with the calculation of Father’s monthly support obligation and filed a petition for judicial review of the FSD support order. Before Mother’s petition could be heard, Mother and Father settled on terms more favorable for Mother than the FSD order. The trial court entered judgment on the basis of the parties’ stipulation. The court then dismissed Mother’s petition for judicial review as moot. Thereafter, Mother filed an application to have FSD pay her attorney fees under Mo. Rev. Stat. 536.087. The trial court dismissed the application, concluding that Mother did not prevail on her petition for judicial review because it became moot when the trial court entered a superseding judgment. Mother appealed, arguing that even though her petition for judicial review was dismissed, she nevertheless prevailed against FSD because the dismissal resulted from a more favorable judgment. The Supreme Court affirmed, holding that because Mother obtained a favorable settlement from Father in this case, rather than FSD, the trial court correctly dismissed Mother’s attorney fee application under section 536.087. View "Garland v. Ruhl" on Justia Law

The Labadie Environment Organization and several individuals (collectively, Appellants) filed a writ of certiorari challenging the legality of the Franklin County Commission’s adoption of zoning amendments allowing Ameren Missouri to build a coal-ash landfill adjoining its Labadie power plant. Count I of the petition alleged that the commission failed to conduct a legally sufficient hearing prior to adopting the zoning amendments, and Count II alleged that the zoning amendments were invalid for failing to promote public health, safety, and welfare. The circuit court entered judgment in favor of the commission and Ameren. The Supreme Court (1) reversed the trial court’s judgment of dismissal on Count I, as Appellants stated a viable claim that the zoning amendments were enacted without a legally sufficient public hearing; and (2) reversed the judgment upholding the merits of the commission’s decision to adopt the landfill zoning amendments, as the commission’s decision to adopt the amendments is premature until Count I is resolved on its merits by the trial court. View "Campbell vs. County Comm’n of Franklin County" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree statutory sodomy, two counts of second-degree statutory sodomy, and one count of attempted first-degree child molestation. The Supreme Court reversed, holding (1) one juror committed misconduct by intentionally withholding material information related to the lawsuit, specifically that the juror formed an opinion about Defendant’s guilt or innocence during voir dire in direct contravention of the circuit court’s instructions that he was prohibited from forming or expressing any opinion about the case; and (2) the evidence was insufficient to convict Defendant of attempted first-degree child molestation. View "State v. Ess" on Justia Law