Justia Missouri Supreme Court Opinion Summaries

The case revolves around Benjamin Ramirez, who, on behalf of a putative class, sued the Director and the Treasurer of the Missouri Department of Revenue in their official capacities. Ramirez had resolved criminal charges against him by pleading guilty and paying court costs, including certain mandatory surcharges. These surcharges were then paid to various funds, as authorized by Missouri statute. Ramirez alleged that the Director and the Treasurer received payment of, collected, and deposited the surcharges in and otherwise managed these funds. He claimed a single count of unjust enrichment and asserted the statutes authorizing the surcharges violate a section of the Missouri Constitution.The Director and the Treasurer moved for summary judgment, asserting that Ramirez’s suit is barred by sovereign immunity and the statutes authorizing the surcharges do not violate the Missouri Constitution. The circuit court sustained the motion, concluding the statutes authorizing the surcharges do not violate the Missouri Constitution. Ramirez appealed this decision.The Supreme Court of Missouri affirmed the circuit court's judgment. The court held that sovereign immunity, a common law judicial doctrine barring suit against a government or public entity, applied to Ramirez's claim for unjust enrichment. The court noted that sovereign immunity is the default rule in all suits against the state and applies to non-tort claims. The court found that the state had not waived its sovereign immunity through express statutory consent or a recognized common law exception. Therefore, Ramirez's unjust enrichment suit against the Director and the Treasurer was barred by sovereign immunity. View "Ramirez vs. Missouri Prosecuting Attorneys' & Circuit Attorneys' Retirement System" on Justia Law

The case involves a group of appellants, collectively referred to as "Challengers", who appealed judgments declaring section 67.1175.1 of the Missouri Statutes constitutionally invalid. This provision, in conjunction with section 67.1177, required a political subdivision to grant public money to a private entity, which was deemed to violate article VI, section 23 of the Missouri Constitution. The circuit court attempted to rectify the constitutional invalidity by modifying section 67.1175.1. The Challengers, however, argued that despite the modification, the sections still required a political subdivision to grant public money to a private entity in violation of the constitution. They further argued that the entire statutory scheme must be struck down because the sections were not severable.The circuit court had declared section 67.1175.1 constitutionally invalid because it mandated the lake area business districts to transfer tax funds to the advisory board, a private nonprofit entity. The court modified the section by removing the phrase "which shall be a nonprofit entity". The Challengers appealed this decision, arguing that the modified sections still violated the constitution.The Supreme Court of Missouri found that the circuit court erred in modifying section 67.1175.1. The court concluded that the section, as modified, and section 67.1177, still required political subdivisions to grant public money to a private entity, violating the Missouri Constitution. The court also concluded that the void provisions were not severable from the remaining provisions of the statutory scheme. As a result, the entire statutory scheme was declared constitutionally invalid. The circuit court’s judgment was reversed, and the Supreme Court entered the judgment the circuit court should have entered, declaring sections 67.1170, 67.1175, 67.1177, and 67.1170 constitutionally invalid and void in their entireties. View "Salamun v. The Camden County Clerk" on Justia Law

Shawn Flaherty was convicted of second-degree domestic assault and armed criminal action following a violent altercation with his wife, during which he brandished a revolver and a bullet from the weapon struck his wife in the knee. Flaherty's defense at trial was that the shooting was accidental, and his counsel requested an instruction for the lesser-included offense of second-degree domestic assault, which the jury ultimately found him guilty of. Flaherty was sentenced to seven years for the assault count and three years for the armed criminal action count, to be served consecutively. His convictions were affirmed on direct appeal.Flaherty subsequently filed a motion for postconviction relief, arguing that his trial counsel was ineffective for failing to request a lesser-included instruction for fourth-degree domestic assault. The motion court overruled Flaherty’s motion after an evidentiary hearing, finding that while his trial counsel's performance was constitutionally deficient for failing to request the instruction for fourth-degree domestic assault, this did not prejudice Flaherty.The Supreme Court of Missouri affirmed the motion court's judgment. The court found that there was sufficient evidence to support the motion court’s finding that counsel’s failure to request the lesser-included instruction for fourth-degree assault did not prejudice Flaherty. The court also noted that the motion court judge, who had also presided over Flaherty's criminal trial, was in a better position to assess the impact of the evidence on the jury and whether it was reasonably likely the jury would have been persuaded by arguments that Flaherty's acts were merely criminally negligent. View "Flaherty v. State" on Justia Law

The case revolves around a dispute over a change of judge in a criminal proceeding. The defendant was charged with a felony, and the original judge recused himself. A new judge was assigned, but the defendant and the prosecutor jointly stipulated to a change of venue and judge. The case was transferred to Butler County and assigned to Judge Pritchett. After Judge Pritchett's retirement, the case was reassigned to Judge Proctor. The defendant then filed a motion for a change of judge, which Judge Proctor sustained. The Attorney General of Missouri, acting as the special prosecutor, filed a petition for a writ of prohibition or mandamus, arguing that the circuit court lacked the authority to sustain the defendant's motion for a change of judge.The court of appeals issued a permanent writ of prohibition and transferred the case to the Supreme Court of Missouri. The defendant did not file a brief but conceded to the Attorney General's writ of prohibition, requesting the case to be reassigned to Judge Proctor for final disposition.The Supreme Court of Missouri found that the defendant's stipulation to a change of venue and judge precluded the circuit court from sustaining the defendant's subsequent motion for a change of judge. The defendant did not allege or show a change of judge was required due to "fundamental fairness" or because Judge Proctor was related to the defendant, had an interest in the case, had been counsel in the proceedings, or disqualified for any other reason. The court concluded that Judge Proctor lacked the authority to sustain the defendant's motion for a change of judge. The court issued a permanent writ of prohibition barring the circuit court from enforcing the order sustaining the defendant's second change of judge. The case remains assigned to Judge Proctor. View "State ex rel. Bailey v. Pierce" on Justia Law

The case involves Robert Anthony Woolery, who was convicted of two counts of delivery of a controlled substance. In 2021, the Sedalia police department identified Woolery as a subject of interest in their investigation into low-to-mid-level drug dealers. The police organized two "controlled buys" from Woolery, using a confidential informant. The transactions were recorded, and the informant produced a bag containing methamphetamine after each buy. Woolery was subsequently charged and convicted.Woolery appealed his conviction, raising five points. He argued that the circuit court erred in not appointing counsel at his initial appearance, in not preserving a transcript or recording of his arraignment, in sentencing him to imprisonment rather than ordering a mental examination, and in overruling his motion to suppress evidence. He also claimed that the detectives lacked authority to respond to emergency situations outside the Sedalia city limits.The Supreme Court of Missouri affirmed the circuit court's decision. The court found that Woolery was not entitled to counsel during his initial appearance and arraignment, either through Rule 31.02(a) or the Sixth Amendment. The court also found that the absence of a transcript or recording of Woolery’s November 15 appearance did not hamper its ability to meaningfully review the points raised by Woolery. The court further held that Woolery failed to establish that manifest injustice or a miscarriage of justice resulted from his sentencing. Finally, the court found that Woolery's claim regarding the denial of his motion to suppress was not preserved for appellate review. View "State of Missouri vs. Woolery" on Justia Law

The case revolves around Troy Jackson-Bey, who was convicted of five counts, including first-degree murder and first-degree assault, following an altercation at a residence. The altercation began when Jackson-Bey and another man argued over a parking issue. Jackson-Bey shot the man, who later died from his injuries. Jackson-Bey then forced his way into the man's home, where he fired his weapon multiple times during a struggle with the man's wife. The wife was not shot. Jackson-Bey appealed his conviction, challenging the admission of surveillance video, the submission of the verdict director for first-degree assault, and the sufficiency of evidence supporting his convictions.The Circuit Court of the City of St. Louis had previously ruled against Jackson-Bey's motion to exclude surveillance video taken from the residence. The court also found there was sufficient evidence supporting Jackson-Bey’s convictions. Jackson-Bey appealed these decisions.The Supreme Court of Missouri affirmed the lower court's decisions. The court found that the circuit court did not err in admitting the surveillance video, as the rule of completeness did not apply. The court also ruled that there was sufficient evidence to support Jackson-Bey’s first-degree assault conviction, as the jury could have reasonably found that Jackson-Bey attempted to kill or cause serious physical injury to the wife. Lastly, the court concluded that age is not an element of the offense of first-degree murder, and thus, it was not necessary for the state to prove Jackson-Bey was 18 years or older at the time of the offense. View "State of Missouri v. Jackson-Bey" on Justia Law

David Steele filed a lawsuit against his employer, Johnson Controls, Inc. (JCI), alleging that the company had violated § 287.780 by retaliating and discriminating against him for filing a workers' compensation claim. Steele sought compensatory and punitive damages, arguing that JCI had acted with willful, deliberate, and reckless disregard for his rights. JCI did not file an answer or responsive pleading, and Steele subsequently filed a motion for default judgment and damages. The circuit court held a hearing regarding damages, during which Steele testified about his injuries and the discriminatory treatment he received from JCI. The court entered a default judgment for Steele, awarding him $300,000 in compensatory damages and $600,000 in punitive damages.JCI filed a motion to set aside the default judgment, citing Rules 75.01, 74.05(d), and 74.06(b)(1). JCI alleged that it had good cause for the default because its registered agent mislabeled the service documents and routed them to the incorrect section of JCI's legal department. The circuit court held a hearing on JCI's motion and subsequently overruled it, concluding that JCI failed to show good cause, a meritorious defense, or excusable neglect. JCI then filed a motion for a new trial, which the circuit court also overruled. JCI appealed the decision.The Supreme Court of Missouri affirmed the circuit court's judgment. The court found that JCI had failed to prove good cause for its default as required to set aside the default judgment pursuant to Rule 74.05(d). The court also found that JCI's reliance on Rules 75.01 and 74.06(b)(1) as alternate bases to set aside the default judgment was incorrect. Finally, the court ruled that JCI's defaulted claims asserting the circuit court plainly erred by awarding punitive damages in violation of § 510.2612 were not reviewable. View "Steele v. Johnson Controls, Inc." on Justia Law

Ashley Colville was charged with second-degree involuntary manslaughter following a motor vehicle accident in St. Louis, Missouri, in which Rodney Larue was fatally injured. The indictment alleged that Colville caused Larue's death by colliding with his vehicle and did so with criminal negligence by failing to yield and use a turn signal. Colville filed a motion to dismiss the indictment, arguing it was insufficient because it failed to state the offense charged.The Circuit Court of St. Louis dismissed the indictment with prejudice. The court held that Colville's alleged failure to yield and signal did not amount to criminal negligence, an essential element of second-degree involuntary manslaughter. The court based its decision on a review of several exhibits, including a video surveillance recording of the accident, and concluded that Colville's actions did not constitute a "gross deviation" that could legally be found criminally negligent.The Supreme Court of Missouri vacated the lower court's judgment and remanded the case for further proceedings. The Supreme Court held that the lower court erred in dismissing the indictment because it was sufficient in all required respects. The court clarified that at the motion to dismiss stage, the court's review of an indictment is limited to determining whether the indictment contains the essential elements of the offense and whether it apprises the defendant of facts constituting the charge. The court found that the indictment against Colville met these requirements. The court also noted that whether the state has satisfied its burden in proving Colville committed the offense charged is not capable of determination without a trial. View "State of Missouri vs. Colville" on Justia Law

In September 2016, Sanford Sachtleben and Luciann Hruza (the Buyers) purchased a property in Missouri from Perry and Joanie Sullivan (the Sellers). Prior to the sale, the city of New Melle had sued the Sellers over a barn they had built on the property, alleging it violated city zoning ordinances. The Buyers were added as defendants to this lawsuit after they purchased the property. The Buyers demanded coverage from their title insurance company, Alliant National Title Insurance Co. (Alliant), but Alliant refused. The Buyers then sued Alliant, claiming it had breached the title insurance policy by refusing to defend them in the New Melle lawsuit.The case was first heard in the Circuit Court of St. Louis County, where Alliant moved for summary judgment. The circuit court granted Alliant's motion, concluding that the unambiguous language of the title insurance policy provided no coverage for the Buyers. The Buyers appealed this decision.The Supreme Court of Missouri affirmed the lower court's decision. The court found that the title insurance policy was unambiguous and did not provide coverage for the Buyers. The court noted that the policy provided coverage only if a notice, describing any part of the land, was recorded in the public records setting forth the violation or intention to enforce. Since no such notice was recorded, the court concluded that the policy did not provide coverage. The court also rejected the Buyers' arguments that other provisions of the policy provided coverage, finding that these arguments were precluded by an exclusion in the policy. View "Sachtleben vs. Alliant National Title Insurance Co." on Justia Law

The case involves Lorandis Phillips, who was convicted of first-degree robbery and second-degree assault. The incident occurred on December 14, 2018, when Phillips and three other men attacked a man in a shed behind Phillips' house. The victim was struck in the head, causing him to fall and lose consciousness briefly. The men then stole his cell phone, wallet, and car keys. Phillips was arrested and charged with the crimes.Phillips appealed his conviction, raising seven points. He argued that he was not represented by counsel at an appearance prior to his preliminary hearing, that the court failed to preserve a recording or transcript of that appearance, that the court erred in allowing his felony information to be amended, that there was insufficient evidence to support a conviction on the robbery count, and that there was a deficiency in the amended information for the assault count.The Supreme Court of Missouri affirmed the lower court's decision. The court found that Phillips' lack of counsel at his initial appearance did not constitute plain error, as he had not shown that he was prejudiced by the absence of counsel. The court also found that the lower court did not err in allowing the felony information to be amended, as the amendment did not prejudice Phillips' substantial rights. The court further found that there was sufficient evidence to support the robbery conviction, and that any deficiency in the amended information for the assault count did not prejudice Phillips. View "State v. Phillips" on Justia Law