Carolyn Holmes filed a wrongful death action under the Federal Employers’ Liability Act against Union Pacific Railroad Company on behalf of her late husband’s estate, alleging his lung cancer resulted from workplace exposure to toxic substances. Union Pacific moved to dismiss because Holmes had not been appointed personal representative of the estate before filing suit, as required by FELA. The circuit court granted her thirty days to obtain the appointment and amend the petition, but Holmes missed the deadline and later sought additional time, claiming excusable neglect. The Missouri Supreme Court affirmed the dismissal, holding that Holmes failed to demonstrate excusable neglect given her extended delay in seeking appointment despite knowing the requirement and prior similar cases involving her counsel.
The case was a wrongful death action brought by the children of a patient against Missouri Delta Medical Center, alleging that negligent care by the center and its employed physicians before, during, and after prostate surgery caused the patient's death. Following a jury trial that awarded economic, noneconomic, and aggravating circumstances damages, the medical center appealed, challenging the submission of aggravating circumstances damages and related procedural issues. The Supreme Court of Missouri affirmed the circuit court's judgment, finding no error in the proceedings, including that the submissibility challenge was properly preserved through motions for directed verdict and that substantial evidence supported the damages award under the applicable statutory standard for health care providers.
SEBA, LLC, operating a donut shop called Eddie’s Southtown Donuts, challenged an assessment by the Missouri Director of Revenue for unpaid state sales taxes, interest, and a five percent addition to tax covering October 2011 through September 2014. The Administrative Hearing Commission upheld the assessment after finding that SEBA failed to maintain adequate records to verify retail and wholesale sales, forcing the auditor to rely on incomplete documentation. On judicial review, the Supreme Court of Missouri affirmed the Commission’s decision, holding that substantial and competent evidence supported both the tax liability and the addition due to SEBA’s negligence in record-keeping under state law.
In State of Missouri v. Rashidi Don Loper, the defendant was convicted by a jury of first-degree attempted rape, multiple counts of domestic assault and armed criminal action, and victim tampering arising from an April 2015 incident in which he attacked E.S.L., his former romantic partner, in her apartment. Loper appealed, arguing that the trial court erred by excluding evidence of E.S.L.'s later conduct, including a 2017 confrontation in which she allegedly tried to assault him with a tire iron, claiming the evidence was needed to show the full context of their relationship and rebut expert testimony on domestic violence patterns. The Supreme Court of Missouri affirmed the convictions, holding that the circuit court did not plainly err in excluding the post-offense evidence as too remote in time to be relevant to E.S.L.'s state of mind during the charged events and noting that Loper had already presented testimony about their tumultuous relationship. The court concluded that the exclusion did not prevent Loper from presenting a complete defense.
The case involved Mary J. Moore, a school bus driver injured when a Metro Call-A-Ride bus collided with her vehicle, who sued Bi-State Development Agency d/b/a Metro and obtained a jury verdict of $1.878 million. Metro sought to reduce the award under section 537.610, which imposes a statutory cap on damages against public entities that have waived sovereign immunity for negligent operation of motor vehicles. Moore argued that section 70.429, which adopts federal regulations requiring certain levels of financial responsibility for transit systems receiving state funding, conflicted with and superseded the damages cap. The Supreme Court of Missouri affirmed the circuit court's reduction of the award, holding that the plain language of the statutes created no conflict and that compliance with federal financial responsibility rules did not waive or alter the per-occurrence liability limit in section 537.610.
This case arose when a former prisoner sued two public defenders for legal malpractice, claiming they failed to challenge the state court's jurisdiction over his burglary and property damage convictions stemming from an offense on federal property. The Missouri Supreme Court reversed the circuit court's judgment upholding a jury verdict for the plaintiff and remanded the case. The court held that public defenders, as state employees performing discretionary duties in client representation, are entitled to official immunity from suit, making that defense dispositive without reaching other issues such as whether a submissible case was made. The decision emphasized that immunity protects against both liability and the burdens of litigation, and coverage under the state legal expense fund does not preclude asserting the defense.
This case involved a legal malpractice claim brought by Dwight Laughlin against his former public defenders, Dewayne Perry and Ellen Flottman, after his state court convictions for burglary and property damage on federal land were vacated for lack of jurisdiction. The circuit court entered judgment for Laughlin following a jury verdict, but the public defenders appealed, claiming official immunity and that Laughlin failed to make a submissible case. The Supreme Court of Missouri reversed the judgment, holding that public defenders are entitled to official immunity because they are state employees whose duties involve discretionary acts in client representation. The court found this immunity dispositive and did not reach the other issues, remanding the case.
This case concerns a juvenile, D.E.G., who appealed the juvenile division's judgment dismissing its jurisdiction over him and transferring his case involving alleged criminal conduct to a court of general jurisdiction after a certification hearing under section 211.071. D.E.G. raised constitutional challenges to the hearing process, including the use of hearsay testimony without personal knowledge and separation of powers concerns. The Supreme Court of Missouri held that a juvenile has a statutory right to appeal from any final juvenile division judgment. The court therefore retransferred the case to the court of appeals for determination of the merits rather than addressing the constitutional claims directly.
David Barnett was convicted of first-degree murder for killing his grandparents in 1996 when he was 19 years old and initially received the death penalty, which was later reduced to life without parole. He challenged the sentencing statute as unconstitutional under the Eighth Amendment, arguing that U.S. Supreme Court precedents limiting life-without-parole sentences for juveniles should apply to him. The Missouri Supreme Court affirmed the sentences, holding that section 565.020 is constitutional as applied because those precedents define juveniles as under 18 and establish a bright-line age limit that does not extend to 19-year-olds. The court reasoned that individualized sentencing considerations based on youth apply only to offenders younger than 18, and any policy changes to expand that definition belong to the legislature.
The case involved Lucille Schoen, a nurse who sought workers' compensation benefits after exposure to an insecticide at work led to medical evaluation where she was accidentally tripped by a dog, resulting in claimed injuries to her knees, back, hip, and neck. The Labor and Industrial Relations Commission denied benefits, finding she failed to prove the work exposure was the prevailing factor causing any permanent disability and that the tripping incident did not arise out of her employment. The Missouri Supreme Court affirmed the Commission's decision, holding that the injury lacked a sufficient causal connection to her job because the risk of tripping was not unique to employment and simple but-for causation was insufficient under the statute. The court also rejected her claim against the Second Injury Fund as moot since no compensable injury existed. The opinion emphasized that for an injury to be compensable, it must arise out of and in the course of employment, not merely occur while engaged in work-related activities.
In State of Missouri v. Duane Michaud, the defendant was convicted by a jury of attempted enticement of a child under section 566.151 after an incident in which he allegedly touched a 14-year-old girl inappropriately while living in the same house. The circuit court sentenced him to five years in prison. On appeal, the defendant argued that the circuit court erred by rejecting his proposed jury instructions (which would have required the jury to find he knew the victim was under fifteen) and by sustaining an objection to proposed testimony about the victim's reputation for truthfulness. The Supreme Court of Missouri affirmed the judgment, concluding there was no instructional error because the attempt statute did not require proof of the defendant's knowledge of the victim's age and no plain error in the evidentiary ruling because the defendant failed to lay a proper foundation or make an offer of proof.
Ronald J. Calzone challenged the constitutionality of two 2016 Missouri bills, SB 638 on elementary and secondary education and SB 665 on agriculture, arguing that amendments during the legislative process violated article III, section 21 (original purpose) and section 23 (single subject) of the Missouri Constitution, and that substantive title changes also breached these provisions. The Supreme Court of Missouri affirmed the circuit court's judgments upholding the bills. The Court reasoned that the bills retained their original purposes throughout the process, that all included provisions were reasonably related to the single subject of each bill, and that titles are not part of the bills themselves so may be amended without violating the constitutional limits. The Court therefore dismissed Calzone's title-change claims for failure to state a claim.
The case involved Ronald J. Calzone's challenges to the constitutionality of two 2016 Missouri bills, SB 638 relating to elementary and secondary education and SB 665 relating to agriculture. Calzone argued that amendments during the legislative process violated article III, section 21 of the Missouri Constitution by changing the bills' original purposes and article III, section 23 by encompassing multiple subjects, and that substantive title changes also breached these provisions. The Supreme Court of Missouri affirmed the circuit court's judgments upholding the bills, holding that each bill retained its original purpose throughout passage, that all provisions were germane to a single subject, and that alterations to the bills' titles did not violate the constitution because the title is not part of the bill itself.
The case involved Meadowfresh Solutions USA, LLC suing Maple Grove Farms, LLC and associated individuals over a dairy farm business, resulting in the circuit court appointing a receiver for Maple Grove. Maple Grove appealed the denial of its motion to revoke or modify that interlocutory receivership order, but the Court of Appeals dismissed the appeal because the order was not denominated a judgment under Rule 74.01(a). The Supreme Court of Missouri held that the order was appealable under sections 515.665 and 512.020(2) without needing to be labeled a judgment, since it was an interlocutory order that did not fully resolve any claim or the parties' rights. The Court overruled inconsistent prior precedent and retransferred the case to the Court of Appeals for merits review.
This case involved a dispute over the administration of a testamentary trust established by Sherlock Hibbs' will, which directed the University of Missouri's Board of Curators to fund specific economics professorships; Hillsdale College filed a declaratory judgment action in St. Louis County alleging improper administration and claiming venue was proper there due to a university campus. The Curators sought a writ of mandamus to transfer the case, arguing that a specific statute governing venue for trust administration proceedings required the matter to be heard in Boone County. The Missouri Supreme Court made the preliminary writ permanent, holding that the action concerned trust administration rather than general contract claims. The Court reasoned that the specific venue provision in section 456.2-204 supersedes the general venue statutes in section 508.010, and because the trust's principal place of administration is in Boone County where the Curators keep the relevant records, that is the proper venue.
The case involved Leslie Seaton's claim for underinsured motorist coverage under three automobile insurance policies issued by Shelter Mutual Insurance Company following the death of her daughter in a car accident. After settling a wrongful death claim against the at-fault driver, Seaton sought additional coverage from Shelter, which paid under one policy but denied the other two on grounds that the daughter did not qualify as an insured. The circuit court granted summary judgment to Seaton, but the Supreme Court of Missouri reversed, holding that the policies' plain language defined an insured to include a relative only if that relative did not own a motor vehicle and that the daughter, who was listed on a vehicle title, failed to meet any of the three definitions of insured. The court further concluded that the policies were not internally inconsistent because coverage was expressly limited to insured persons. The case was remanded for further proceedings.
This case involved Gary Sampson, who pleaded guilty to drug possession in 2012 and was placed on probation multiple times after revocations. Sampson petitioned for a writ of mandamus after the circuit court denied his motion for discharge from probation and scheduled a violation hearing, arguing that a third probation term was invalid and that earned compliance credits should have ended his supervision earlier. The Missouri Supreme Court held that the circuit court exceeded its authority by imposing the third probation term following a 120-day treatment program but found it unclear whether the valid second term had expired with credits applied. The Court therefore issued a permanent writ ordering the circuit court to reinstate the second probation term so that earned compliance credits could be properly recalculated. The decision focused on statutory limits on probation authority under sections 559.036 and 217.703 rather than personal or subject-matter jurisdiction.
Trevor Griffith filed a habeas corpus petition claiming the circuit court lacked authority to impose a third five-year probation term after revoking his second probation following a 2010 guilty plea to felony drug distribution. The Supreme Court of Missouri held that the circuit court erred by placing Griffith on an unauthorized third probation term but exercised discretion to address the merits despite the case becoming moot after Griffith's release from incarceration and discharge from parole in February 2019. The court reasoned that an erroneous third probation requires remand to the point of the invalid placement for resentencing, yet Griffith's completed sentence and release made any further custody or remand unnecessary. The opinion declined to return Griffith to custody solely to correct the procedural error.
The case involved Lance Shockley’s appeal from the denial of his Rule 29.15 post-conviction motion challenging his first-degree murder conviction and death sentence for killing a Missouri highway patrol sergeant who had been investigating him. After a jury found Shockley guilty and could not agree on punishment, the trial court imposed death following its independent review under state statute; this Court previously affirmed the conviction and sentence on direct appeal. In the post-conviction proceeding, Shockley claimed ineffective assistance of trial counsel, primarily related to handling of potential juror misconduct involving exposure to a novel containing anti-defendant content. The Supreme Court of Missouri affirmed the motion court’s denial of relief after an evidentiary hearing, holding that the claims did not establish a basis for setting aside the conviction or sentence. The court exercised exclusive jurisdiction due to the death penalty.
This case involved two employees who filed charges with the Missouri Commission on Human Rights alleging violations of the Missouri Human Rights Act. Lampley claimed sex discrimination and retaliation based on his non-stereotypical male appearance and behavior as a gay man, while Frost claimed retaliation and discrimination due to her association with Lampley. The Commission administratively closed the complaints, determining they alleged discrimination based on sexual orientation rather than a protected category under the Act. The circuit court granted summary judgment to the Commission, but the Supreme Court of Missouri reversed that judgment and remanded the case, holding that the complaints sufficiently alleged sex discrimination through gender stereotyping.