Justia Constitutional Law Opinion Summaries

St. Louis City’s Ordinance 70078 establishes a citywide local minimum wage. The trial court invalidated the Ordinance because it requires a higher minimum wage than the state requires in Mo. Rev. Stat. 290.502. In so ruling, the trial court concluded that Mo. Rev. Stat. 71.010, which includes a general prohibition on local laws that conflict with state laws, would bar such supplemental local minimum wage ordinances. The Supreme Court reversed the portion of the judgment invalidating Ordinance 70078, holding (1) the trial court correctly found that Mo. Rev. Stat. 67.1571 does not preempt Ordinance 70078 because section 67.1571 was enacted in a manner that violates Mo. Const. art. III, 23; (2) Missouri’s minimum wage law does not occupy the field of minimum wage laws, nor does it prohibit the adoption of local minimum wage ordinances such as Ordinance 70078; and (3) Ordinance 70078 is within the municipality’s police powers, and the City did not exceed its authority in enacting the minimum wage ordinance. View "Cooperative Home Care, Inc. v. City of St. Louis" on Justia Law

David DePriest and Natalie DePriest, brother and sister, were charged separately with offenses arising from their cultivation of marijuana plants. The DePriests were represented by the same counsel throughout their separate criminal proceedings. The DePriests jointly pleaded guilty pursuant to a plea deal on counsel’s recommendation. The trial court accepted both DePriests’ pleas. Thereafter, the DePriests filed separate motions for postconviction relief pursuant to Mo. R. Crim. P. 24.035, alleging ineffective assistance of counsel because defense counsel continued to represent both of them long after it became clear during the plea negotiations that there was an actual conflict of interest between them. The motion court denied both motions without an evidentiary hearing. The Supreme Court vacated the motion court’s judgments and remanded the cases for further proceedings, holding that both David and Natalie alleged sufficient facts to state a claim of ineffective assistance of counsel under Rule 24.035, and therefore, the motion court erred in denying the DePriests an evidentiary hearing. Remanded. View "DePriest v. State" on Justia Law

At issue in this case was a proposed ordinance establishing a minimum wage for Kansas City. The City of Kansas City filed an action seeking to have the trial court order the Kansas City Board of Election Commissioners and other election authorities serving the City to remove from the November 3, 2015 ballot the proposed ordinance, arguing that, if enacted, the ordinance would conflict with Mo. Rev. Stat. 285.055. Several individuals (collectively, the Committee), who proposed the ordinance using the initiative petition provisions of the Kansas City Charter, intervened in the City’s action, arguing that the proposal should remain on the ballot. The trial court entered judgment for the City and ordered that the measure be removed, concluding that the proposed ordinance was inconsistent with section 285.055. The Supreme Court reversed, holding that the claims of the City and the Committee were premature. View "City of Kansas City v. Kansas City Board of Election Commissioners" on Justia Law

A juvenile officer filed a petition to terminate the parental rights of Father, who was in prison, and Mother. After a trial, the circuit court entered a judgment terminating both parents’ parental rights. The court found that termination was in the best interest of Child and, with respect to Father, found three separate grounds for termination, including the ground that Father was unfit to be a party to the parent-child relationship pursuant to Mo. Rev. Stat. 211.447.5(6)(a). On appeal, Father challenged, among other things, the constitutional validity of section 211.447.5(6)(a). The Supreme Court affirmed, holding (1) section 211.447.5(6)(a) is not unconstitutionally vague as applied to Father’s case; (2) the circuit court’s findings were supported by substantial evidence and were not against the weight of the evidence; and (3) Father’s challenges to the circuit court’s procedural rulings were unavailing. View "In re Interest of J.P.B." on Justia Law

Defendant was arrested and charged with possessing and attempting to use as genuine a forged social security card. Defendant was being held without bail, as provided in his arrest warrant. Counsel for Defendant subsequently filed a motion asking the trial court to release Defendant on his own recognizance or, alternatively, to set reasonable conditions for his release. The trial court overruled the motion pursuant to Mo. Rev. Stat. 544.470.2. Defendant sought review, arguing that section 544.470.2 violates article I, section 20 of the Missouri Constitution because the last sentence of the statute prohibits the trial court from considering conditions for a defendant’s release under Mo. Rev. Stat. 544.455 unless and until the defendant proves his “lawful presence in the United States.” The Supreme Court agreed, holding that the wholesale denial of pretrial release for an entire class of defendants under section 544.470.2 violates the right to reasonable and individualized bail set forth in article I, section 20. Remanded with directions that the trial court consider reasonable conditions for Defendant’s release using the individualized procedure set forth in Mo. Rev. Stat. chapter 544 and Mo. R. Crim. P. 33. View "Lopez-Matias v. State" on Justia Law

Defendant was charged with first-degree murder and armed criminal action. Prior to trial, Defendant filed a motion to suppress statements he made to police after being read his Miranda rights. The trial court sustained the motion, concluding that Defendant’s statement, “I ain’t signing shit without my attorney” was an invocation of his right to counsel. The Supreme Court reversed, holding that Defendant failed to clearly and unequivocally assert his Fifth Amendment right to counsel, and even assuming Defendant’a partially invoked his right to counsel, there was no Fifth Amendment violation when the police questioned Defendant after he refused to sign a consent to search form. View "State v. Holman" on Justia Law

After a jury trial, Defendant was convicted of second-degree burglary and stealing. The convictions were affirmed on direct appeal. Thereafter, Defendant filed a petition for post-conviction relief, arguing that his counsel was ineffective for failing to request an instruction on the lesser-included offense of trespass as an alternative instruction to second-degree burglary. The circuit court overruled Defendant’s motion following an evidentiary hearing. The Supreme Court affirmed, holding that counsel’s performance did not fall below an objective standard of reasonableness under the performance prong of Strickland v. Washington and that there was no need to address the prejudice prong. View "McNeal v. State" on Justia Law

This case centered around Amendment No. 3, a constitutional amendment proposed by initiative petition. After the Secretary of State certified Amendment No. 3 for the November 8, 2016 general election ballot, various individuals (collectively, “Opponents”) brought three separate cases pursuant to Mo. Rev. Stat. 116.200.1 seeking to reverse this decision. The trial court entered judgment against the Opponents. The Supreme Court affirmed, holding (1) the proponents submitted a sufficient number of valid signatures in support of the amendment to qualify for the ballot; (2) the amendment does not, on its face, amend or create more than one article of the Missouri Constitution; (3) the amendment does not violate the constitutional prohibition against appropriation by initiative; and (4) the remainder of the Opponents’ substantive challenges were premature. View "Boeving v. Kander" on Justia Law

After a jury trial, Defendant was found guilty of first-degree assault and armed criminal action. Defendant appealed, arguing that the trial court erred in denying his challenge during voir dire to one of the prosecutor’s peremptory strikes under Batson v. Kentucky because the prosecutor failed to offer a race-neutral explanation for striking the venireperson. The Supreme Court vacated Defendant’s convictions, holding that the trial court clearly erred in denying Defendant’s Batson challenge where the prosecutor failed to offer a reasonably specific and clear race-neutral explanation for the strike. Remanded. View "State v. Meeks" on Justia Law

In April 2015, the Missouri General assembly passed House Bill 150 (HB 150), which made changes to Missouri’s unemployment benefits compensation statutes. The Governor subsequently vetoed HB 150. In September 2015, during a veto session, the Missouri Senate reconsidered HB 150 and voted to override the governor’s veto. Appellants filed a declaratory judgment action seeking a declaration that HB 150 is unconstitutional and requested an injunction prohibiting HB 150 from being executed or enforced. The Supreme Court reversed, holding that the Senate lacked authority to vote to override the Governor’s veto during the veto session because only bills returned by the Governor on or after the fifth day before the end of the regular legislative session can be taken up during a September veto session. View "Pestka v. State" on Justia Law