Justia Constitutional Law Opinion Summaries

Defendant was charged with first degree assault and an associated armed criminal action count under Mo. Rev. Stat. 571.015.1. Defendant, who was a juvenile at the time of the offenses, moved to dismiss the armed criminal action charge on the ground that the application of the sentencing provisions of section 571.015.1 to juvenile offenders is unconstitutional. The trial court agreed with Defendant, concluding that section 571.015.1 is unconstitutional as applied to all juvenile offenders and declared unconstitutional the three-year mandatory minimum incarceration requirement for juveniles who are certified to stand trial as adults. The State subsequently filed this interlocutory appeal challenging the trial court’s determination regarding the constitutional validity of section 571.015.1. The Supreme Court dismissed the State’s appeal, holding that the State has no right to appeal this interlocutory decision under section 547.200.1, nor does the trial court’s decision constitute a final judgment from which the State is entitled to appeal under section 547.200.2. View "State v. Smiley" on Justia Law

The City of De Soto and a De Soto resident (collectively, Appellants) filed suit against the governor and attorney general (collectively, Respondents) seeking a declaratory judgment that Mo. Rev. Stat. 321.322.4 violates the prohibition against special laws contained in Mo. Const. art. III, 40. The trial court granted summary judgment in favor of Respondents. The Supreme Court reversed, holding (1) section 321.322.4 is a special law in violation of Mo. Const. art. III, 40; (2) consequently, the State was required to provide a substantial justification for enacting the statute rather than a general law; and (3) because the State offered no such evidence, entry of judgment for the State was error. View "City of DeSoto v. Nixon" on Justia Law

The Metropolitan St. Louis Sewer District (MSD) brought claims of inverse condemnation, trespass, and negligence against the City of Bellefontaine Neighbors for damages caused to MSD sewer lines during the course of a city street improvement project. The City moved to dismiss, alleging that inverse condemnation does not apply to public property and that sovereign immunity applied and had not been waived. The trial court entered judgment in favor of the City. The Supreme Court affirmed, holding that MSD failed to state an inverse condemnation claim, and sovereign immunity barred MSD’s tort claims against the City. View "Metro. St. Louis Sewer Dist. v. City of Bellefontaine Neighbors" on Justia Law

A police officer searched a plastic grocery bag that Defendant was holding after he was already handcuffed and seated in the police car. Inside the bag the officer discovered heroin. Defendant was charged with the class C felony of drug possession. Defendant filed a motion to suppress evidence of the heroin, arguing that neither the arrest nor the search of his plastic bag was lawful. The circuit court overruled the motion, and Defendant was convicted. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in overruling Defendant’s motion to suppress evidence of the heroin because (1) the arrest of Defendant was lawful; and (2) the search of Defendant’s bag was not a lawful search incident to arrest, but the exclusionary rule did not apply to this case. View "State v. Carrawell" on Justia Law

Gerald Geier, an accountant, was the treasurer of Stop Now!, a Missouri political action committee (PAC). Geier was required to register the PAC with the Missouri Ethics Commission (MEC). Stop Now! became inactive after 2003, and the PAC’s bank account closed in 2006. When Stop Now! failed to file disclosure reports for the first three quarters of 2011, the MEC opened an investigation. The MEC subsequently filed a complaint against Geier and Stop Now!, alleging that they violated Mo. Rev. Stat. 13.046.1, 130.021.4(1) and 130.021.7 by failing to timely file disclosure reports and failing to notify the MEC of the closure of the PAC’s bank account. After a hearing, the MEC found probable cause that Geier and Stop Now! knowingly violated the applicable statutes. Geier sought judicial review, challenging, inter alia, the constitutional validity of the reporting statutes. The circuit court granted summary judgment in favor of the MEC. The Supreme Court affirmed, holding (1) the reporting statutes are constitutional as applied; (2) Geier’s challenges to the facial validity of the reporting statutes are not ripe; (3) section 105.961.3, the statute that requires the MEC’s hearings be closed to the public, does not violate the First or Sixth Amendments; and (4) the MEC had authority to investigate Geier. View "Geier v. Missouri Ethics Comm’n" on Justia Law

New Garden Restaurant, Inc. received “estimated audit assessments” from the Department of Revenue notifying New Garden that it owed $43,738 in unpaid sales tax. New Garden claimed it never received final assessment notices sent by the Department of Revenue. New Garden appealed the Director of Revenue’s tax assessments against it more than two weeks past the deadline. The Administrative Hearing Commission entered a summary decision dismissing New Garden’s appeal, ruling that it had no authority to hear New Garden’s appeal because the appeal was not filed within the time limitation for doing so. The Supreme Court affirmed, holding (1) under the circumstances of this case, there was no due process violation; (2) equitable estoppel does not excuse New Garden’s late filing; and (3) the Commission did not err in its findings. View "New Garden Restaurant, Inc. v. Dir. of Revenue" on Justia Law