Justia Missouri Supreme Court Opinion Summaries

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Commercial Barge Line (CBL) was a Delaware corporation and the single member of two limited liability companies, one of which was American Commercial Barge Line (ACBL). In 2007, the Department of Revenue (DOR) conducted an audit and determined that CBL and ACBL (together, Taxpayers) owed Missouri sales and use tax on goods and supplies delivered to ACBL’s towboats while the towboats traveled south on the Mississippi River. Taxpayers sought review of these assessments. The Administrative Hearing Commission (AHC) upheld the DOR’s determination that Taxpayers owed Missouri sales and use tax on the goods and supplies at issue. The Supreme Court affirmed the decision of the AHC, holding (1) the sales and use tax assessments did not violate the Commerce Clause because the supplies were purchased or used within Missouri and were fairly related to the services the Taxpayers received from the state; (2) the taxes did not violate the Maritime Transportation Security Act because they were assessed on ACBL’s purchases and deliveries of supplies and not on the towboats; and (3) the relevant statute of limitations did not bar the DOR from assessing tax liability for the audit period, 2001 through 2006. View "Commercial Barge Line Co. v. Dir. of Revenue" on Justia Law

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Appellant was charged with fourteen offenses, including one count of forcible rape, one count of aggravated stalking, and five counts of violating a protective order. Appellant was convicted of all counts and sentenced to a fifty-year term of imprisonment for forcible rape under Mo. Rev. Stat. 566.030.2. The Supreme Court affirmed Appellant’s convictions and sentences, holding (1) Appellant’s sentence for forcible rape did not exceed the maximum sentence for that offense where section 566.030.2 authorizes a range of punishment from five years to life imprisonment; and (2) Appellant’s convictions for aggravated stalking and violating a protective did not violate double jeopardy. View "State v. Hardin" on Justia Law

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Respondent, a Mississippi corporation with operations in several states, including Missouri, established a “rabbi trust” to fund its executive deferred compensation plan for company executives. In filing its 2007 Missouri corporate income tax return, Respondent reported income from the rabbi trust as “non-business” income and, therefore, reported and allocated all trust income to Mississippi and paid Mississippi income taxes on that income. The Missouri director of revenue determined that the trust income was business income subject to apportionment and taxation in Missouri. On appeal, the Administrative Hearing Commission concluded that the trust income was non-business income. The Supreme Court reversed, holding that the trust income was business income “used for the current operational purpose of attracting and retaining key employees” and was therefore subject to apportionment in Missouri. View "MINACT, Inc. v. Dir. of Revenue" on Justia Law

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In 2006, Appellant was injured in the course and scope of his employment when a large metal beam crushed his left foot. Appellant received workers’ compensation benefits for his injury. Appellant subsequently returned to work for Employer on “light duty.” Appellant was on a break to rest his foot when Employer’s owner terminated him. Thereafter, Appellant filed a claim of retaliatory discharge against Employer. A jury entered a verdict in favor of Employer. The Supreme Court reversed, holding (1) to make a submissible case for retaliatory discharge under Mo. Rev. Stat. 287.780, an employee must demonstrate his or her filing of a workers’ compensation claim was a “contributing factor” to the employer’s discrimination or the employee’s discharge; and (2) the trial court erred in instructing the jury that it had to determine Appellant was discharged exclusively in retaliation for filing a workers’ compensation claim. Remanded for a new trial. View "Templemire v. W&M Welding, Inc." on Justia Law

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After Appellant was convicted of felony driving while intoxicated (DWI), the director of revenue suspended Appellant’s driving privileges for a minimum of ten years. Appellant later filed a petition for limited driving privileges. The circuit court dismissed Appellant’s petition, determining that Appellant was statutorily ineligible for limited driving privileges pursuant to Mo. Rev. Stat. 302.309.3(6)(b) due to his felony conviction. Appellant appealed, asserting that section 302.309.3 violated the equal protection clause of the state and federal constitutions by allowing DWI court participants and graduates to obtain reinstatement of limited driving privileges while denying a similar opportunity to non-participants. The Supreme Court affirmed, holding that Appellant failed to establish that section 302.309.3 violated his right to equal protection. View "Amick v. Dir. of Revenue" on Justia Law

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Appellant was a Missouri corporation that sold rides on untethered hot air balloons. Appellant collected sales tax on receipts of balloon rides and subsequently requested a refund of those sales taxes from the director of revenue. The director denied Appellant’s request. The director also assessed sales taxes on the amount paid to Appellants by third-party vendors and use taxes on a hot air balloon and inflator fan purchased in Texas. The administrative hearing commission (AHC) denied Appellant’s claim for a refund of the sales taxes paid and Appellant’s challenge to the assessment of sales and use taxes. The Supreme Court (1) reversed the ruling of the AHC as to the assessment of sales taxes on all sales of hot air balloon rides - those purchased directly from Appellant in Missouri and those purchased by flight certificate from out-of-state third-party vendors - because the taxes on those gross receipts were state taxes on air commerce, which are prohibited by the Anti-Head Tax Act; and (2) affirmed the AHC in regard to the assessed use taxes, holding that Appellant was liable for use taxes on equipment purchased outside of Missouri. View "Balloons Over the Rainbow, Inc. v. Dir. of Revenue" on Justia Law

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After a jury trial, Defendant was convicted of second degree murder, second degree assault, and endangering the welfare of a child. The Supreme Court affirmed the convictions, holding (1) the trial court did not err in overruling Defendant’s motions for judgment of acquittal on each offense for which she was convicted, as there was sufficient evidence from which a reasonable juror could find Defendant guilty of each offense; and (2) because the State presented evidence that sufficiently established the corpus delecti of the murder offense, Defendant failed to establish facially substantial grounds for believing that the trial court committed clear error in admitting into evidence statements Defendant made to the police as evidence of guilt of murder in the second degree. View "State v. Jones" on Justia Law

Posted in: Criminal Law
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In 2010, Father, a California resident, sent his children (Children) to Missouri, and later that year, the Children began to live with their mother. In 2011, the Children were taken into protective custody. In 2012, the circuit court found that the record supported three separate legal grounds for termination of Father’s parental rights, including neglect, and concluded that termination of parental rights would be in the Children’s best interest. The court of appeals affirmed the judgments terminating Father’s parental rights. The Supreme Court affirmed, holding that the circuit court’s determinations that Father neglected the Children and that it was in the best interest of the Children to have Father’s parental rights terminated were supported by substantial evidence. View "In re J.A.R." on Justia Law

Posted in: Family Law
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Plaintiffs in this action included St. Louis County, the county superintendent of police, the county sheriff, and a deputy sheriff. Plaintiffs filed a petition seeking a declaratory judgment that the deputy sheriff salary supplementation fund established by Mo. Rev. Stat. 57.278 was unconstitutional and improperly administered. The circuit court dismissed the case on the grounds that none of Plaintiffs had standing and that all claims were barred by sovereign immunity. The Supreme Court (1) reversed the judgment to the extent that it dismissed Count IV, in which Plaintiffs alleged that the rejection of their application to obtain a grant from the fund was arbitrary and an abuse of discretion, as, under the facts of this case, the superintendent had a legal interest in obtaining judicial review of whether he was a county sheriff who was eligible to file a grant application; and (2) affirmed the remainder of the judgment. Remanded. View "St. Louis County v. State" on Justia Law

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Appellant filed this action seeking a declaratory judgment that a gravel road running along the edge of his property belonged to him and was not a public road. The trial court granted summary judgment against Appellant, concluding that the road was a public county road by operation of Mo. Rev. Stat. 228.190.2, which provides that a road for which a county receives county aid road trust funds for at least five years is “conclusively deemed to be a public county road.” The Supreme Court affirmed but on other grounds, holding that because Appellant failed to show he had a current ownership interest in the strip of land on which the road runs, Appellant failed to show an interest in the lawsuit sufficient to give him standing to bring this action. View "Brehm v. Bacon Township" on Justia Law