Justia Constitutional Law Opinion Summaries

Articles Posted in Supreme Court of Missouri
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The Supreme Court affirmed in part and vacated in part the judgment of the circuit court rejecting Plaintiffs' claims challenging the refusal by the Department of Social Services (DSS) to provide MO HealthNet coverage, holding that the circuit court erred in declaring Mo. Const. art. IV, 36(c) constitutionally invalid.Plaintiffs, three Missourians eligible for MO HealthNet coverage under article IV, section 36(c), brought this action challenging the DSS's refusal to provide coverage on the grounds that the General Assembly failed to appropriate adequate funding. The circuit court rejected the claims, finding that the ballot initiative that enacted article IV, section 36(c) violated Mo. Const. art. III, 51, which prohibits initiatives from appropriating money without creating revenue to fund the initiative. The Supreme Court affirmed in part and vacated in part the circuit court's judgment, holding (1) article IV, section 36(c) does not appropriate money and does not remove the General Assembly's discretion in appropriating money to MO HealthNet; and (2) therefore, the circuit court erred in concluding that article IV, section 36(c) violates article III, section 51. View "Doyle v. Tidball" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court finding the challenged provisions of House Bill No. 1413 violated multiple provisions of the Missouri Constitution and permanently enjoining its operation and enforcement, holding that HB 1413 is void in its entirety.HB 1413, which was enacted in 2018, significantly altered many aspects of public labor relations in the state. The circuit court found (1) the exemption of public safety labor organizations in Mo. Rev. Stat. 105.503.2(1) violates public employees' right to bargain collectively through representatives of their own choosing, in violation of article I, section 29; and (2) the exemption of public safety labor organizations violated Mo. Const. art. I, 29. The Supreme Court affirmed, holding (1) the circuit court did not err in finding that the exemption of public safety labor organizations violates multiple provisions of the Missouri Constitution and in permanently enjoining Defendants from administering or enforcing any provision of HB 1413; and (2) the operation of the subject exemption forces the Court to declare HB 1413 void in its entirety rather than sever the offending provision. View "Missouri National Education Ass'n v. Missouri Department of Labor & Industrial Relations" on Justia Law

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The Supreme Court vacated and remanded the judgment of the circuit court dismissing Appellants' lawsuit against the Missouri Sheriffs' Retirement System (MSRS), holding that the statute authorizing a $3 surcharge violates Mo. Const. art. I, 14.At issue was Mo. Rev. Stat. 57.955, which provides that a $3 surcharge shall be assessed and collected in all state civil actions and in all criminal cases including violation of criminal or traffic laws, including infractions. Appellants received speeding tickets and pled guilty and paid court costs. Unbeknownst to Appellants was that three dollars of the total costs was the surcharge authorized by section 57.955. Appellants, on behalf of a putative class, sued MSRS, alleging that the purchase violated article I, section 14 of the Missouri Constitution. The circuit court dismissed the case, concluding (1) Appellants failed to join the clerks responsible for assessing, collecting, and remitting the surcharge as necessary and indispensable parties; and (2) the statute was not unconstitutional. The Supreme Court reversed, holding (1) the municipal court clerks were not necessary and indispensable parties; and (2) section 57.955 is not "reasonably related to the expense of the administration of justice" and therefore violates article I, section 14 of the Missouri Constitution. View "Fowler v. Missouri Sheriffs' Retirement System" on Justia Law

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The Supreme Court affirmed the decision of the circuit court granting judgment on the pleadings in favor of the Affton Fire Protection District, the governor, and the attorney general (collectively, Defendants) in this challenge to Mo. Rev. Stat. 72.418.2 and 321.322.3, holding that the circuit court did not err.The City of Crestwood and two of its resident taxpayers (collectively, Plaintiffs) argued that sections 72.418.2 and 321.322.3, which govern the provision of and payment for fire protection services in certain annexed areas, violate the prohibition against special laws in Mo. Const. art. III, 40 and that section 72.418.2 violates constitutional due process protections and provisions of the Missouri Constitution prohibiting certain taxes and the creation of unfunded mandates. The Supreme Court held (1) a rational basis supported the classification scheme in sections 72.418 and 321.322.3; (2) the fee Crestood pays to the district is not a tax on the resident taxpayers of Crestwood; and (3) section 72.418.2 does not create an unfunded mandate. View "City of Crestwood v. Affton Fire Protection District" on Justia Law

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The Supreme Court vacated the judgment of the motion court overruling Appellant's pro se Rule 29.15 postconviction motion seeking to vacate his felony statutory sodomy conviction under Mo. Rev. Stat. 566.062, holding that there was no final judgment in the underlying criminal case, and therefore, Appellant's postconviction relief motion was premature.In his motion for postconviction relief, Appellant argued that he received ineffective assistance of trial counsel. After an evidentiary hearing, the motion court overruled the motion on the merits. Appellant appealed, arguing that his postconviction relief motion was premature because the trial court failed to carry out the Supreme Court's mandate issued in his direct appeal, and therefore, his judgment of conviction was not yet final. The Supreme Court agreed, holding (1) the trial court failure strictly to comply with the Court's mandate; and (2) therefore, the judgment of condition in Appellant's criminal case was not yet a final judgment that triggers the running of the time period in which he can file a Rule 29.15 motion, and the Rule 29.15 motion was premature. View "Lemasters v. State" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court judgment overruling Defendant's Mo. Rev. Stat. 29.15 motion for postconviction relief from his death sentence for first degree murder, holding that the circuit court's findings of fact and conclusions of law were not clearly erroneous.On appeal, Defendant argued that the circuit court committed multiple errors affecting the guilt phase, penalty phase, and postconviction relief phases of his criminal case. Among other things, Defendant argued that the circuit court erred in failing to find that his counsel provided ineffective assistance in several respects. The Supreme Court affirmed, holding that the circuit court's findings of fact and conclusions of law were not clearly erroneous and that the circuit court did not err in denying postconviction relief. View "McFadden v. State" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court committing Appellant to the department of mental health (DMH) as a sexually violent predator (SVP), holding that the circuit court did not err.In 2005, Appellant pleaded guilty to felony sex abuse. Before his release in 2016, the State filed a petition seeking to civilly commit him as an SVP. A jury found Appellant to be an SVP and the circuit court committed him to DMH. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion when it prohibited Appellant from questioning the jury panel about the specific ages of child victims; (2) the circuit court did not err when it excluded a portion of the testimony regarding Appellant's risk of future dangerousness; (3) the circuit court did not plainly err in submitting Instruction No. 6, the verdict director; (4) Appellant received effective assistance of counsel at his probable cause hearing; (5) the circuit court did not plainly err in overruling Appellant's motion for new trial based on juror nondisclosure of bias; (6) Appellant's claim of ineffective assistance of counsel for failure to move for change of venue was without merit; and (7) omissions in the trial transcript did not prejudice Appellant's appellate review. View "In re Care & Treatment of D.N." on Justia Law

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The Supreme Court affirmed the judgment of the circuit court sentencing Defendant to two terms of life imprisonment without the possibility of parole, holding that Mo. Rev. Stat. 565.020 is constitutional as applied to Defendant.Defendant was nineteen years old when he killed his grandparents. Defendant was convicted of two counts of first-degree murder and sentenced to death for each murder count. Later, a federal district court ordered the state of Missouri either to sentence Defendant to life without the possibility of probation or parole or grant him a new penalty phase trial. On remand, Defendant argued that section 565.020, which then provided that first-degree murder shall be punishable either by death or imprisonment for life without eligibility for probation or parole, was unconstitutional as applied to him because offenders who commit crimes at nineteen years old also display the transient, hallmark features of adolescence affecting risk and impulse control. The circuit court rejected Defendant's claims and sentenced him to life without the possibility of parole on both murder counts. The Supreme Court affirmed, holding that where Supreme Court precedent clearly defines a juvenile as an individual younger that eighteen years of age for purposes of the considerations Defendant sought, section 565.020 was constitutional as applied to Defendant. View "State v. Barnett" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court to the extent it enjoined the State from prohibiting unobtrusive picketing about matters of public concern in negotiations for a new labor agreement with the CWA Local 6360, holding that Mo. Rev. Stat. 105.585(2)'s prohibition against "picketing of any kind" is unconstitutional, but severance of the phrase renders the provision constitutional.The circuit court enjoined the State from enforcing or implementing section 105.585(2)'s mandated prohibition against "picketing of any kind" in negotiating a collective bargaining agreement with certain public employees. In so holding, the circuit court declared section 105.585(2) unconstitutional under both the state and federal constitutions as it relates to picketing. The Supreme Court affirmed, holding (1) section 105.585(2) violates Mo. Const. art. I, 8; (2) severance of the portion of the statute prohibiting "picketing of any kind" is applicable and appropriate; and (3) permanent injunction was the appropriate remedy in this case. View "Karney v. Department of Labor & Industrial Relations" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court granting summary judgment in favor of the State on the petition for declaratory and injunctive relief filed by Thomas Sager and the Missouri Coalition for the Environment (collectively, the Coalition) claiming Senate Bill No. 35 (SB 35), now codified at Mo. Rev. Stat. 34.030, violates the Missouri Constitution, holding that summary judgment was properly granted.In the petition, the Coalition claimed, among other things, that SB 35 violated the single-subject and clear-title requirements in Mo. Const. art. III, 23, that the bill's original purpose changed prior to final passage in violation of the original-purpose requirement of article III, section 21, that SB 35 implicitly amended other laws governing the Missouri Department of Natural Resources, and that the full text of those others laws should have been set out in the final bill pursuant to article III, section 28. The Supreme Court disagreed, holding that the SB 35 did not violate the state constitution in any of the ways argued by the Coalition. View "Missouri Coalition for Environment v. State" on Justia Law