Justia Constitutional Law Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's medical malpractice case without prejudice for failure to file an affidavit of merit within 180 days pursuant to Mo. Rev. Stat. 538.225, holding that there was no error.On appeal, Appellant argued (1) section 538.225 violates multiple provisions of the Missouri Constitution, (2) the defense of failure to file an affidavit of merit was waived, and (3) he substantially complied with the statute. The Supreme Court affirmed, holding (1) Appellant's constitutional claims were without merit; (2) section 538.225 is not an affirmative defense that can be waived if not pleaded in an answer; and (3) to the extent substantial compliance with section 538.225 is possible, Appellant failed to substantially comply. View "Giudicy v. Mercy Hospitals East Communities" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of three counts of first-degree statutory sodomy and three counts of incest and sentencing him to a total of eighty-seven years' imprisonment, holding that there was no error.On appeal, Defendant argued that the circuit court erred in admitting evidence pursuant to Mo. Const. art. I, 18(c), overruling objections to the State's closing argument, admitting expert testimony and particular exhibits, and finding sufficient evidence to support the convictions. The Supreme Court affirmed, holding that there was no error, plain or otherwise, or abuse of discretion in the proceedings below. View "State v. Minor" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of tampering with a judicial officer and second-degree harassment of his probation officer, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) Defendant's facial overbreadth challenge to the second-degree harassment statute, Mo. Rev. Stat. 565.091, was without merit; (2) there was sufficient evidence to support Defendant's conviction for second-degree harassment; and (3) the district court did not violate Defendant's right to be free from double jeopardy when it sentenced Defendant for both tampering with a judicial officer and second-degree harassment. View "State v. Collins" on Justia Law

The Supreme Court dismissed this appeal from the judgment of the circuit court granting summary judgment on one of Respondent's three claims, holding that the circuit court's judgment was not a "final judgment" for purposes of Mo. Rev. Code 512.020(5).Respondent, Jefferson County 9-1-1 Dispatch, filed an action seeking a declaratory judgment, a writ of mandamus, and injunctive relief preventing Appellant, the Director of the Department of Revenue, from enforcing Mo. Rev. Stat. 190.327.5. Respondent argued that the statute violated three different provisions of the Missouri Constitution. The circuit court entered judgment for Respondent on one of its claims, but the remaining two claims were neither denied nor dismissed. Appellant appealed. The Supreme Court dismissed the appeal, holding that the circuit court's judgment was not a final judgment for purposes of section 512.020(5). View "Jefferson County 9-1-1 Dispatch v. Plaggenberg" on Justia Law

The Supreme Court vacated the judgment of the circuit court granting the State's Rule 74.06(b)(5) motion for relief from its 2016 judgment permanently enjoining the State from enforcing Mo. Rev. Stat. 67.287 and Mo. Rev. Stat. 479.359.2, holding that the circuit court erred.In 2016, the circuit court permanently enjoined the State from enforcing sections 67.287 and 479.359.2 after finding those sections to be unconstitutional special laws. Three years later, the Supreme Court decided City of Aurora v. Spectra Communications Group, LLC, 592 S.W.3d 764 (Mo. banc 2019), which restored the rational basis analysis for social law claims. Thereafter, the State filed a motion for relief from judgment. The circuit court granted the motion. The Supreme Court vacated the judgment, holding that the circuit court improperly assumed a change in decisional law was sufficient to warrant relief from judgment pursuant to Rule 75.06(b)(5). View "City of Normandy v. Parson" on Justia Law

The Supreme Court reversed the judgment of the circuit court sustaining the State's motion for judgment on the pleadings and dismissing Plaintiffs' action seeking a declaration that the Second Amendment Protection Act (SAPA), Mo. Rev. Stat. 1.410 through 1.485, is unconstitutional and requesting injunctive relief, holding that Plaintiffs had no adequate remedy at law other than to pursue their declaratory judgment action.Plaintiffs - the City of St. Louis, St. Louis County, and Jackson County - brought this action challenging SAPA. The State filed a motion for judgment on the pleadings, alleging that Plaintiffs had adequate remedies at law. The circuit court sustained the motion, finding that Plaintiffs had an adequate remedy at law because multiple individual lawsuits were pending in which Plaintiffs could bring their constitutional challenges. The Supreme Court reversed, holding that Plaintiffs lacked an adequate remedy at law in which to adjudicate their specific constitutional challenges. View "City of St. Louis v. State" on Justia Law

The Supreme Court vacated the judgment of the circuit court convicting Defendant of fifteen counts of unlawful possession of a firearm following a jury trial, holding that the circuit court committed reversible error by allowing the jury to hear a prejudicial, out-of-court statement made by a witness who never appeared or testified at trial.After Defendant was arrested on allegations of domestic violence against his wife, Beckey, Beckey told officers that Defendant illegally possessed numerous firearms. Defendant was subsequently charged with fifteen counts of unlawfully possessing a firearm. During trial, the out-of-court statement made by Beckey, who did not appear at trial, was elicited during an officer's testimony. The circuit court ruled that Beckey’s statement could be considered as substantive evidence. Defendant was subsequently convicted. The Supreme Court vacated the conviction, holding that the circuit court prejudicially erred in allowing the officer's testimony over Defendant's violation. View "State v. Hollowell" on Justia Law

The Supreme Court affirmed the judgment of the circuit court reducing the jury's punitive damages award against HALO Branded Solutions, Inc., holding that the circuit court's application of the punitive damages cap in Mo. Rev. Stat. 510.265 did not violate All Star Awards & Ad Specialities Inc.'s right to a jury trial, and the reduced award did not violate HALO's due process rights.All Star brought this action against HALO and All Star's employee, Doug Ford. A jury found HALO tortiously interfered with All Star's business expectancy, that Ford breached his duty of loyalty to All Star, and that HALO conspired with Ford to breach this duty of loyalty. The jury awarded All Star $525,542 in actual damages and assessed $5.5 million in punitive damages against HALO. The circuit court applied section 510.265 and capped the punitive damages award at five times All Star's actual damages - or $2,627,709 - and entered final judgment in accordance with the jury's verdicts. The Supreme Court affirmed, holding (1) the circuit court properly reduced All Star's award of punitive damages; and (2) the reduced award was within the constitutional parameters of due process. View "All Star Awards & Ad Specialties, Inc. v. HALO Branded Solutions, Inc." on Justia Law

The Supreme Court affirmed the judgment of the circuit court determining that Mo. Rev. Stat. 595.201, as applied to defense attorneys, is constitutionally invalid and that the passage of Senate Bill 569 (SB 569) was procedurally proper, holding that the circuit court did not err in its judgment.Plaintiffs - five public defenders and three criminal defendants - brought this action for declaratory and injunctive relief challenging the constitutional validity of statutes relating to victims of sexual offenses, including SB 569 and section 595.021, which requires criminal defense attorneys to provide information to victims of sexual assault offenses. The circuit court (1) declared section 595.201 constitutionally invalid as as applied to defense counsel because it violated defense attorneys' rights to freedom of speech, and (2) rejected procedural challenges to SB 569 as a whole. The Supreme Court affirmed, holding that the circuit court properly determined that (1) section 595.201.2(4)'s requirements violate defense attorneys' free speech rights, and (2) the General Assembly complied with the procedural limitations imposed by the Missouri Constitution in passing SB 569. View "Fox v. State" on Justia Law

The Supreme Court vacated the order of the circuit court entering a declaratory judgment that Mo. Rev. Stat. 115.646 violated public officials' right to free speech and was void for vagueness, holding that the circuit court erred.Section 115.646 prohibits officials from directly using public funds to advocate, support, or oppose a ballot measure or candidate for public office. Plaintiffs initiated a lawsuit seeking a judgment declaring section 115.646 unconstitutional. The circuit court sustained Plaintiffs' motion for summary judgment, declaring that section 115.646 violated the officials' First Amendment rights. The Supreme Court vacated the judgment, holding (1) because section 115.646 regulates the use of public funds, not the officials' speech, it does not implicate the free speech clause of the First Amendment; and (2) the circuit court erred in declaring certain words and phrases in the statute to be unconstitutionally vague. View "City of Maryland Heights v. State" on Justia Law