Mary Rhodes Russell

The case involved a challenge by registered Missouri voters to the results of the November 2024 election approving Proposition A, an initiative that would raise the minimum wage to $15 per hour by 2026, index it to inflation thereafter, and require employers to provide paid sick leave. Contestants claimed the ballot title's summary statement and fiscal note summary were so misleading as to create an election irregularity sufficient to invalidate the results under sections 115.555 and 115.593, and further alleged that Proposition A violated the single-subject and clear-title requirements of article III, section 50 of the Missouri Constitution. The Supreme Court of Missouri ruled that the ballot title was not unfair or insufficient and that contestants failed to meet the high burden of showing an irregularity casting doubt on the election's fairness, thereby upholding the election results as valid. The court dismissed the single-subject and clear-title claims without prejudice, holding that it lacked original jurisdiction over those issues.

electionslabor & employmentbusiness & regulatory

In State of Missouri v. Anthony Tate, the defendant appealed his convictions for two counts of first-degree assault after a jury trial, arguing insufficient evidence and that the trial court plainly erred by not issuing a corrective instruction during the State's closing argument or striking portions of a detective's testimony as inadmissible hearsay. The Supreme Court of Missouri affirmed the circuit court's judgment, holding that the evidence—including video surveillance, ballistics, social media posts, and medical records showing gunshot wounds—was sufficient to support the convictions. The court further concluded that Tate failed to demonstrate any manifest injustice or miscarriage of justice from the unobjected-to statements or the admission of the hospital records, as the testimony was not decisive and the jury did not rely on the unadmitted portions.

criminal lawprocedure

The case concerned Safeco Insurance Company's appeal from the denial of its motion to intervene in a state-court wrongful death action brought by Jeromy McCrackin against Tynan Mullen, who had been convicted in connection with the shooting death of McCrackin's son; Safeco sought intervention solely to request a stay of the tort suit until its separate federal declaratory judgment action could determine whether the homeowners policy issued to Mullen's grandmother provided coverage or a duty to defend. The Supreme Court of Missouri vacated the circuit court's judgment and remanded for further proceedings. It held that Safeco satisfied the requirements of Rule 52.12(a)(2) for intervention as of right because it possessed an interest in the litigation that could be impaired if the wrongful death action proceeded without it. The court explained that an insurer facing coverage questions may protect its position by filing a declaratory judgment action and seeking a limited stay of the underlying tort case, and that denying intervention in these circumstances was error.

proceduretorts & liabilitybusiness & regulatory

In State of Missouri v. Chad Thomas, the defendant appealed his convictions for possession of a controlled substance and unlawful possession of drug paraphernalia, arguing that evidence found during a traffic stop for a broken headlight should have been suppressed because the officer unlawfully extended the detention without reasonable suspicion. The Supreme Court of Missouri affirmed the circuit court's judgment, holding that the officer's actions did not violate the Fourth Amendment. The court reasoned that the totality of the circumstances—including Thomas's unusual behavior when rolling down his window, inability to locate his license, statements about a possible "sharp," nervous demeanor, attempts to close the vehicle door, and movements blocking the officer's view—provided objective reasonable suspicion of criminal activity, justifying the continued detention and canine sniff that led to the discovery of the evidence. The detention lasted less than 30 minutes and was limited to the time needed to investigate the suspicion.

criminal lawprocedurecivil rights

The case concerned challenges by property owners in lake area business districts in Camden and Miller counties to Missouri statutes (sections 67.1170, 67.1175, 67.1177, and 67.1180) that authorized creation of these districts, governed by nonprofit advisory boards elected by lodging businesses, with power to impose and spend lodging taxes on tourism promotion. The circuit court found the scheme violated the Missouri Constitution's prohibition on political subdivisions granting public money to private entities (article VI, section 23) and attempted to modify one provision to cure the defect. The Supreme Court of Missouri held that the statutes, even as modified, on their face required public funds to be given to private entities and that the invalid provisions were not severable from the rest of the scheme because the creation, operation, and dissolution of the districts were inseparably connected to the unconstitutional advisory board and tax provisions. Accordingly, the Court reversed the circuit court, declared the entire statutory scheme void, and ordered appointment of trustees to wind up and dissolve the existing districts.

taxesbusiness & regulatory

The case involved Troy Jackson-Bey appealing his convictions on five counts, including first-degree murder and first-degree assault, from a June 2020 shooting during an argument over parking at a St. Louis residence. The Missouri Supreme Court affirmed the circuit court's judgment, finding no error in admitting portions of surveillance video from a motion-activated system, submitting the first-degree assault verdict director, or determining that sufficient evidence supported the convictions. The court reasoned that the video evidence complied with applicable rules, the jury instructions accurately reflected the charges, and the state was not required to prove the defendant's age as an element of first-degree murder since the defendant bore the burden on any age-based mitigation claim. Jackson-Bey did not produce evidence disputing his age, and the judgment was upheld.

criminal lawprocedure

Rachel Sender sued the City of St. Louis for negligence after sustaining injuries in a bicycle accident on a bike path in Forest Park, claiming defects in the path caused her fall. The circuit court dismissed the claims with prejudice after an evidentiary hearing, finding that Sender's pre-suit notice letter failed to adequately identify the accident location as required by section 82.210 and that the bike path qualified as a thoroughfare under the statute. On appeal, the Supreme Court of Missouri affirmed the dismissal, holding that the bike path met the definition of a thoroughfare because it formed part of a continuous public traffic route, thereby triggering the statutory notice obligation. The Court further concluded it could not review the circuit court's determination that the notice was insufficient because Sender failed to include the transcript of the evidentiary hearing in the appellate record.

torts & liabilityprocedure

This case concerned a putative class action lawsuit filed by Jackson County property owners against the county and its officials, alleging that increases in assessed property values were unlawful due to the county's failure to provide timely notice under state statutes and to conduct required physical inspections. The circuit court denied the county's motion to dismiss, prompting the county to seek a writ of mandamus from the Missouri Supreme Court. The Supreme Court made its preliminary writ permanent, ordering dismissal of the underlying action. The court reasoned that the taxpayers had failed to exhaust available administrative remedies, such as appealing assessments to the county board of equalization or the state tax commission, before filing suit, as required by Missouri's property tax statutes and longstanding exhaustion doctrine.

taxespropertyprocedure

This case involved Maryann Gray's workers' compensation claims for injuries sustained while working as a nurse at Hawthorn Children's Psychiatric Hospital in 2012, 2013, and 2014; an administrative law judge denied all claims in September 2019. Gray mailed applications for review to the Labor and Industrial Relations Commission on September 30, 2019, within the 20-day statutory deadline, but the mailing was returned for insufficient postage due to a postal service error; she later sent the applications by fax and a second mailing that included the original returned envelope, which the Commission received on November 1. The Commission found the applications timely under section 287.480 based on evidence of the September 30 postmark and sufficient postage, denied Hawthorn's motion to strike, and issued final awards granting partial benefits on some claims. Hawthorn appealed, arguing the Commission lacked jurisdiction because the applications were untimely and never properly received. The Supreme Court of Missouri affirmed, holding that the Commission's factual findings were conclusive and established timely filing by mail under the statute's plain language.

labor & employmentprocedure

Aaron Hecker appealed the denial of his Rule 24.035 motion for postconviction relief following guilty pleas to second-degree assault of a special victim and resisting arrest. He claimed his attorney provided ineffective assistance by failing to investigate his competency to proceed, citing his schizophrenia diagnosis, prescribed medications, and prior mental health history. The Supreme Court of Missouri affirmed the circuit court's judgment, holding that counsel was not ineffective because Hecker appeared to understand the proceedings, was taking his medications without exhibiting delusions or confusion, and counsel had monitored his competence throughout. The court distinguished prior cases where additional mental health evaluations were required due to different factual circumstances, such as post-plea suicide attempts or unmedicated psychoses.

criminal lawprocedure

In Patriots Bank v. Black River Motel, LLC, the bank sought appointment of a receiver under the Missouri Commercial Receivership Act for four LLCs and a corporation after they defaulted on separate loans secured by liens on their real and personal property. The circuit court appointed a receiver ex parte on an emergency motion and later overruled the borrowers' motion to vacate the order. On appeal, the Supreme Court of Missouri affirmed, holding that the seven days' notice given to the borrowers satisfied the statute and due process, that the circuit court did not rely on post-order events when denying the motion to vacate, and that the receiver order complied with the MCRA's requirements without improperly delegating rights or exceeding statutory authority.

business & regulatorypropertyprocedure

The case involved a petition for a writ of habeas corpus filed by Johnny A. Johnson, who was sentenced to death, seeking to prevent his execution on the grounds that he is incompetent to be executed and that his severe mental illness makes the execution unconstitutional under the Eighth and Fourteenth Amendments. The Missouri Supreme Court denied the petition and overruled the motion for a stay of execution as moot. The court reasoned that Johnson's mental illness claims were procedurally barred because similar arguments had been rejected on direct appeal, and he failed to make the required substantial threshold showing of insanity under the standards set by Panetti v. Quarterman and Ford v. Wainwright, as his evidence was not credible in light of conflicting reports.

criminal lawcivil rightsprocedure

In State of Missouri v. Jason Michael Hurst, the defendant appealed his convictions for first-degree tampering and resisting arrest after he stole a police vehicle while handcuffed and led officers on a high-speed chase exceeding 10 miles, during which he drove recklessly and endangered others. The charges arose from an eviction incident where Hurst, under the influence of drugs, refused to leave and resisted arrest, leading to a physical altercation with officers before he fled in the patrol car. Hurst requested jury instructions on the defense of necessity, arguing his actions were justified to protect himself and his wife from alleged police abuse, but the circuit court declined to give them. The Supreme Court of Missouri affirmed the convictions, holding that there was not substantial evidence to support submitting a necessity defense to the jury for either charge. The court reasoned that Hurst's subjective beliefs and the objective facts did not meet the legal requirements for the defense under section 563.026.

criminal lawprocedure

The case involved James Swafford's appeal from the denial of permanent total disability benefits from Missouri's Second Injury Fund following a 2017 work-related right shoulder injury. Swafford, who had preexisting conditions including ankylosing spondylitis and cardiac issues, argued that these disabilities combined with his primary injury to render him permanently and totally disabled. The Supreme Court of Missouri affirmed the Labor and Industrial Relations Commission's decision overruling the claim. The court held that Swafford failed to show his preexisting disabilities directly and significantly aggravated or accelerated the primary injury, as required by section 287.220.3(2)(a)a(iii).

labor & employment

Gary Weibrecht appealed the denial of benefits from Missouri's Second Injury Fund after a 2016 lower back injury, alleging that preexisting injuries combined to render him permanently and totally disabled. The administrative law judge applied section 287.220.3 (governing post-2014 injuries per the Cosby precedent) and denied the claim for lack of evidence that preexisting conditions met the 50-week threshold or other statutory criteria, while also overruling multiple post-hearing motions to reopen the record for additional evidence. The Labor and Industrial Relations Commission affirmed the award and the denial of the motions. The Missouri Supreme Court affirmed, concluding the Commission did not abuse its discretion in refusing to reopen the record after the hearing concluded.

labor & employmentprocedure

Thomas Dubuc appealed the denial of permanent total disability benefits from Missouri's Second Injury Fund following a 2015 workplace fall that injured his wrist, kidneys, and back, asserting that his preexisting conditions like hernias combined with the primary injury to cause total disability. The Supreme Court of Missouri affirmed the Labor and Industrial Relations Commission's decision, holding that the Commission did not abuse its discretion by denying Dubuc's post-remand motion for additional discovery and evidence after the Cosby ruling clarified the applicable statute. The court further determined that section 287.220.3 governed the claim because the primary injury occurred after January 1, 2014, and Dubuc failed to establish any medically documented preexisting disabilities that directly and significantly aggravated or accelerated his primary injury as required by that provision. The core reasoning centered on the plain meaning of the statutory requirements for Fund liability in post-2014 injury cases and the lack of sufficient medical documentation meeting those criteria.

labor & employmentprocedure

The case concerned whether a solar energy system owned by Springfield Solar 1, LLC, located on property owned by City Utilities of Springfield, qualified for a property tax exemption under Missouri statute section 137.100(10) as a "solar energy system not held for resale." The Assessor and Greene County challenged the exemption, arguing the statute was unconstitutional under article X, section 6 of the Missouri Constitution, which limits tax exemptions to those enumerated in the constitution. The circuit court had upheld the exemption and ruled the Assessor could not disregard the statute absent a court declaration of unconstitutionality. The Supreme Court of Missouri held that the statute is unconstitutional because the constitution does not grant the legislature authority to create exemptions for solar energy systems, as sections 4(a) and 4(b) do not provide implied power to exempt property beyond the explicit allowances in sections 4(c), 6, and 7. The court vacated the judgment, ruled the equipment taxable, and remanded the case.

taxesproperty

The case involved Jim Swoboda filing a charge of discrimination with the Missouri Commission on Human Rights against Armstrong Teasdale, LLP, alleging retaliation, disability discrimination, and aiding and abetting for actions related to his testimony in a prior discrimination case against his employer, the Board of Police Commissioners. The Commission dismissed the charge for lack of jurisdiction due to the absence of an employer-employee relationship with the law firm. Swoboda sought judicial review, and the circuit court issued a permanent writ of mandamus directing the Commission to rescind the dismissal and investigate the charge. The Supreme Court of Missouri reversed, holding that Swoboda failed to establish entitlement to mandamus relief because the Commission properly dismissed the charge under the Missouri Human Rights Act, which requires an employment relationship for such claims, and the 2017 amendments did not alter that requirement for entities qualifying as employers.

labor & employmentcivil rights

In this case, Bruce Schlafly sued his sister Anne Cori for abuse of process, alleging she filed a lawsuit challenging amendments to their mother's trust not to achieve a legitimate legal outcome but to pressure him into resigning from family organizations, ceding his inheritance, and incurring litigation costs. The circuit court dismissed the petition for failure to state a claim. The Missouri Supreme Court reversed the dismissal, finding that the allegations in the petition sufficiently stated the elements of an abuse of process claim under the deferential standard for reviewing motions to dismiss, as they described uses of the legal process for ends outside the intended purpose of the trust suit.

family lawproceduretorts & liability

The case involved Christopher Klecka appealing the Labor and Industrial Relations Commission's denial of permanent total disability benefits from Missouri's Second Injury Fund following a 2014 work-related left shoulder injury. Klecka had settled his primary claim and sought Fund benefits by combining that injury with several preexisting conditions, including a 1981 traumatic brain injury, a 1982 knee surgery, and work injuries from 2005, 2006, and 2007. The Supreme Court of Missouri affirmed the Commission's decision reversing an administrative law judge's award in Klecka's favor. The court held that section 287.220.3 limits consideration to the primary injury and any qualifying preexisting disabilities of at least 50 weeks of permanent partial disability, and Klecka's experts had improperly factored in non-qualifying conditions when opining on permanent total disability, leaving no evidence that the primary injury plus the sole qualifying prior shoulder injury caused total disability.

labor & employmentprocedure