Justia Missouri Supreme Court Opinion Summaries

Driver was arrested for driving while intoxicated (DWI). The Director of Revenue (DOR) subsequently suspended Driver's license and disqualified him from driving a commercial motor vehicle. Driver filed a petition for a trial de novo in the trial court challenging the constitutional validity of Mo. Rev. Stat. 302.700 and 302.755, which disqualify drivers who are convicted of an alcohol-related traffic offense from driving a commercial vehicle for not less than one year. The trial court ruled that sections 302.500 and 302.700 violated the U.S. Constitution based on National Federation of Independent Business v. Sebelius (hereinafter NFIB) and reinstated Driver's driving privileges, including his commercial driver's license (CDL). The Supreme Court (1) reversed the trial court's judgment as to the constitutional validity of section 302.700 under NFIB, holding that NFIB was inapplicable to Driver's argument; and (2) denied Driver's due process and equal protection arguments, finding that they were without merit.View "Bone v. Dir. of Revenue" on Justia Law

Plaintiff owned and operated a public golf course and rented golf carts to golfers. The director of revenue issued an assessment of unpaid sales taxes on the golf cart rentals, finding that because the cart rentals were mandatory, they were subject to sales tax regardless of the fact that Plaintiff had paid sales tax when it purchased the carts. The administrative hearing commission reversed, finding that Plaintiff did not owe sales tax on the golf cart rentals because it previously paid sales tax on its purchase or lease of the carts. The Supreme Court affirmed, holding that, pursuant to Mo. Rev. Stat. 144.020.1(8) and Westwood Country Club v. Director of Revenue, Plaintiff was not required to charge sales tax on the golf cart rentals.View "PF Golf, LLC v. Dir. of Revenue" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to death. Defendant subsequently filed a motion for post-conviction relief. The motion court denied the motion after an evidentiary hearing on five of Defendant's fourteen allegations of error. The supreme Court affirmed, holding, among other things, that the motion court did not clearly err in (1) denying Defendant's claim that his trial counsel were ineffective for failing to investigate and present a diminished capacity defense; (2) failing to find the State committed a Brady violation; and (3) failing to find Defendant's trial counsel were ineffective for failing to object to the admission of a reenactment video without an evidentiary hearing.View "Johnson v. State" on Justia Law

The marriage of Husband and Wife was dissolved in 2003. In 2005 and 2006, the trial court reduced Husband's child support obligations and made no change to his maintenance obligation. While Husband's second appeal was pending, Wife filed a motion for attorney's fees on appeal. The trial court ordered Husband to pay $7,500 of Wife's attorney fees on appeal. The Supreme Court affirmed, holding (1) Mo. Rev. Stat. 452.355, which grants the circuit court subject matter jurisdiction to enter an award of attorney fees on appeal while the appeal is pending, is not unconstitutional; (2) section 452.355 is not unconstitutionally vague because it provides sufficient guidance so as to allow a person of ordinary intelligence to understand the standards to be applied by the circuit court in making an award of attorney fees; and (3) the trial court did not abuse its discretion in awarding Wife attorney's fees on appeal.View "Goins v. Goins" on Justia Law

Trish Carcopa purchased a unit in Parkway Towers, a condominium, and later executed a quit claim deed conveying the unit to herself and Nicole Carcopa. Nicole subsequently executed an adjustable rate note that was a refinancing of the original purchase-money lien. The note was secured by a deed of trust that was held by Appellant at the time of this dispute. Parkway Towers brought a petition to judicially foreclose on its lien, alleging that Trish and Nicole failed to pay their assessments and dues and asserting it had a first and prior lien on the unit. The trial court found Parkway Towers' lien was superior to Appellant's deed of trust and ordered Parkway Towers' lien to be judicially foreclosed. Appellant appealed, claiming Mo. Rev. Stat. 448.3-116 was unconstitutionally vague and ambiguous with respect to its application to determine priority between a refinancing deed of trust and a delinquent condominium association assessment. The Supreme Court affirmed, holding that the statute was not vague and ambiguous and that Appellant's lien did not receive priority.View "Bd. of Managers of Parkway Towers Condo. Ass'n v. Carcopa" on Justia Law

Defendant pleaded guilty to two counts of failure to register as a sex offender pursuant to a plea agreement. After judgment was entered, Defendant filed a timely amended post-conviction motion seeking to vacate the judgment against him, contending that his plea counsel was ineffective and that the plea and sentencing court erred. Defendant’s post-conviction counsel subsequently withdrew from the case, and a second appointed lawyer filed a late second amended post-conviction motion. The circuit court overruled Defendant’s second amended motion without an evidentiary hearing, concluding that the record refuted Defendant’s claims. The Supreme Court affirmed, holding (1) the arguments raised in the late-filed second amended motion were time-barred; and (2) the motion court did not err in finding that Defendant was not entitled to a hearing on the claims raised in his first amended motion because the claims were refuted by the record. View "Stanley v. State" on Justia Law

Plaintiff filed an action against his employer, BNSF Railway Company, for damages related to an injury he sustained while in the course and scope of his employment. Plaintiff asserted claims for negligence under the Federal Employers’ Liability Act (FELA). The trial court granted judgment in favor of BNSF. Defendant appealed, asserting three claims of error relating to the trial court’s exclusion of certain evidence at trial. The Supreme Court affirmed the judgment in all respects, holding that the trial court did not abuse its discretion in its evidentiary rulings challenged by Plaintiff. View "Lozano v. BNSF Ry. Co." on Justia Law

Karen Chastain submitted to the Kansas City Clerk an initiative petition seeking adoption of an ordinance that would impose additional sales taxes for “capital improvements” and “transportation purposes.” The City filed a petition seeking a declaration that the proposed ordinance violated Mo. Const. art. III, 51. The trial court declared that the proposed ordinance was unconstitutional because the ordinance was used for the appropriation of money. The Supreme Court reversed, holding that the trial court erred in concluding that the ordinance violated article III, section 51 because the ordinance merely imposed additional sales taxes, and there was no appropriation. Remanded. View "City of Kansas City v. Chastain" on Justia Law

Plaintiff was injured in an automobile accident. Group Health Plan, Inc. (GHP) paid Plaintiff’s medical bills. Plaintiff subsequently recovered a personal injury settlement from the tortfeasor. GHP, through its agent, ACS Recovery Services, Inc. (ACS), asserted a lien against Plaintiff’s settlement, seeking reimbursement or subrogation for its payment of Plaintiff’s medical bills. Plaintiff filed a class action petition against GHP asserting several claims based on the premise that Missouri law does not permit the subrogation of tort claims. ACS intervened. The trial court entered summary judgment for GHP and ACS, concluding that the Federal Employee Health Benefits Act (FEHBA) preempts Missouri’s anti-subrogation law. The Supreme Court reversed, holding that FEHBA does not preempt Missouri law barring subrogation of personal injury claims. Remanded. View "Nevils v. Group Health Plan, Inc." on Justia Law

At issue in this case was HB 1171, which authorized the establishment of a county municipal court. Petitioners, residents and taxpayers of Franklin County, filed a declaratory judgment action against the commissioners of the County after the commissioners entered an order establishing a municipal court. Petitioners alleged that (1) HB 1171’s enactment violated the original purpose provision of Mo. Const. art. III, 21 and the single subject provision of Mo. Const. art. III, 23; and (2) the commissioners’ order was unconstitutional as a result of HB 1171’s constitutional invalidity. The circuit court dismissed the petition, concluding that Plaintiffs lacked standing and that the lawsuit was not ripe for review. The Supreme Court reversed, holding (1) Plaintiffs had standing to proceed with their claim that the legislation at issue was enacted in violation of procedural constitutional provisions; and (2) the suit was ripe for review. Remanded. View "LeBeau v. Comm’rs of Franklin County" on Justia Law