Justia Missouri Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the circuit court denying Plaintiff's challenge to the constitutional validity of Mo. Rev. Stat. 303.390, which prohibited Plaintiff from collecting noneconomic damages in her personal injury lawsuit filed against Defendant, with whom she had been in a motor vehicle accident, holding that Plaintiff was not entitled to relief.At the time of the underlying accident, Plaintiff was an uninsured motorist prohibited from recovering noneconomic damages under section 303.390. The circuit court awarded Plaintiff economic damages for her medical bills but denied her renewed motion to strike Defendant's affirmative defense regarding section 303.390. The Supreme Court affirmed, holding that Plaintiff failed properly to preserve her constitutional argument for appellate review. View "Bridegan v. Turntine" on Justia Law

The Supreme Court reversed the judgment of the circuit court dismissing Petitioner's petition seeking relief from fraudulent transfers Respondent made to hinder collection of her judgments against him, holding that Petitioner adequately alleged facts that, if true, entitled her to relief under the Uniform Fraudulent Transfers Act (UFTA), Mo. Rev. Stat. 428.005 to 428.059.On appeal, Petitioner argued that she alleged facts that, if taken as true, demonstrated that she was Respondent's creditor and that he made two transfers with the actual intent to hinder, delay, or defraud her and, regarding one of the transfers, without receiving an equivalent value in exchange and either was insolvent or became insolvent as a result of the transfer. The Supreme Court agreed and remanded the case, holding that Petitioner adequately pleaded a claim for relief under both Mo. Rev. Stat. 428.024.1(1) and Mo. Rev. Stat. 928.029.1. View "Konopasek v. Konopasek" on Justia Law

The Supreme Court vacated the decision of the circuit court sustaining Defendant's motions to suppress evidence obtained after his warrantless arrest for a felony, holding that to the extent the decision was based on Defendant's claim that the Fourth Amendment is violated when an arresting officer was outside of the officer's jurisdiction unless the officer personally observed the crime, the decision was clearly erroneous.Defendant was charged in two separate cases for his involvement in two robberies. Defendant moved to suppress evidence obtained after a warrantless arrest, arguing that his Fourth Amendment rights were violated because the officer was outside of his jurisdiction. The circuit court sustained the motions to suppress. The Supreme Court vacated the circuit court's decision, holding that while Moore v. State, 458 S.W.3d 822 (Mo. banc 2015), requires both probable cause and that the crime be committed in the officer's presence for an arrest to satisfy the Fourth Amendment, when a warrantless arrest is for a felony, the Fourth Amendment is satisfied if the arresting officer has probable cause for the arrest, even when the felony was not committed in the arresting officer's presence. View "State v. Barton" on Justia Law

The Supreme Court affirmed the judgment of the circuit court, holding that the Missouri Constitution does not permit the General Assembly to limit the Conservation Commission's authority to expend and use conservation funds for constitutionally-enumerated purposes.The General Assembly enacted House Bill No. 2019 in 2020, appropriating $21 million to the Conservation Commission. The General Assembly, however, removed language from HB 2019 regarding use of the Commission's funds, including for land acquisition and payments in lieu of taxes (PILT). Later, the Commission attempted to withdraw funds to pay for a land acquisition and for PILT, but the Office of Administration denied the requests. The Commission and the Missouri Department of Conservation brought this action against the Attorney General and the Commissioner of the Office of Administration seeking declaratory relief to require certification of PILT payments. The circuit court ordered the Commissioner to certify the land purchase and PILT payments as requested. The Supreme Court affirmed, holding that, in passing HB 2019, the General Assembly invaded the Commission's constitutional authority by attempting to limit the constitutionally-enumerated purposes for which the Commission could use its funds. View "Conservation Comm'n v. Bailey" on Justia Law

The Supreme Court affirmed Defendant's conviction for first-degree statutory sodomy, incest, first-degree child molestation, and one count of first-degree attempted rape, holding that the circuit court's jury instructions did not violate Defendant's constitutional right to a unanimous verdict.On appeal, Defendant argued that the evidence presented at trial included multiple allegations of abuse related to each count of sexual misconduct and that five separate verdict directors violated his constitutional right to a unanimous jury verdict. The Supreme Court affirmed, holding that the jury instructions violated Defendant's right to a unanimous verdict. View "State v. Hamby" on Justia Law

The Supreme Court affirmed the order of the circuit court overruling Appellants' motion to vacate the court's order appointing a receiver for Appellants, holding that the petition filed by Patriots Bank seeking the appointment of a receiver pursuant to the Missouri Commercial Receivership Act (MCRA), Mo. Rev. Stat. 515.500-515.665, did not violate due process.Bank entered into lending relationships with Appellants, all of which defaulted. Bank filed a petition seeking the appointment of a receiver for Appellants. The circuit court entered the receiver order. The Supreme Court affirmed, holding (1) the Bank complied with the plain language of the MCRA's notice requirement; (2) the application of the MCRA to Appellants' case did not violate the due process protections under either the state or federal constitutions; (3) the circuit court did not abuse its discretion in overruling Appellants' motion to vacate the receiver order; and (4) the receiver order did not violate the MCRA. View "Black River Motel, LLC v. Patriots Bank" on Justia Law

The Supreme Court affirmed the judgment of the circuit court affirming the decision of the director of revenue to suspend Defendant's driver's license pursuant to Mo. Stat. 302.505, holding that the circuit court did not err in admitting testimony that a preliminary breath test was greater than 0.08 percent or in finding that Defendant was arrested upon probable cause for an alcohol-related offense.Specifically, the Supreme Court held (1) the result of a preliminary breath test is a numerical percentage by weight of alcohol in the blood of the test person, and section 577.021.3 allows a court to admit the result as evidence of probable cause to arrest; (2) because the numerical result in this case was known to the arresting officer at the time of arrest the circuit court was allowed to consider it in determining that the officer had probable cause to arrest Defendant; and (3) the judgment was supported by substantial evidence and was not against the weight of the evidence. View "Wilmoth v. Director of Revenue" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of possessing a controlled substance, in violation of Mo. Rev. Stat. 579.015.1, and unlawfully using a weapon while in possession of a controlled substance, in violation of Mo. Rev. Stat. 571.030.1, holding that Defendant's convictions did not infringe upon his right to be free from double jeopardy.On appeal, Defendant argued that his convictions violated double jeopardy protections because they arose from the same conduct. The Supreme Court reversed, holding that no double jeopardy violation existed because the plain language of the states combined with fundamental principles of statutory interpretation clearly demonstrated the legislature's intent to authorize multiple punishments under sections 579.015 and 571.030.1(11). View "State v. Onyejiaka" on Justia Law