Justia Civil Rights Opinion Summaries

Defendant pleaded guilty to first degree assault and armed criminal action (ACA). Defendant subsequently filed a motion for post-conviction relief pursuant to Mo. R. Crim. P. 24.035, alleging ineffective assistance of counsel. The circuit court dismissed the motion as untimely filed because Defendant filed it within 180 days of his delivery to the department of corrections for his first degree assault sentence, which triggered the period in which he could file a post-conviction relief motion challenging that conviction and sentence. The court of appeals affirmed, holding that the triggering event was Defendant's previous delivery to the department of corrections to serve his ACA sentence imposed in the same judgment. The Supreme Court affirmed, holding (1) the circuit court did not err in dismissing Defendant's motion as to his claim of ineffective assistance of plea counsel because the claim was not timely filed; and (2) Defendant's claim that his counsel at his probation revocation hearing on his assault conviction was ineffective was not cognizable in a Rule 24.035 proceeding. View "Swallow v. State" on Justia Law

Employee was terminated from her employment after her driver's license was suspended due to her epilepsy. Employee filed this action against Employer, alleging discrimination and retaliation in violation of the Missouri Human Rights Act (MHRA). The jury returned a verdict in favor of Employee in the amount of $11,250 for compensatory damages. Employee filed a motion for additur or, in the alternative, a new trial. The circuit court sustained Employee's motion and gave the parties thirty days to accept a higher amount of compensatory damages or elect a new trial on these damages only. Employer would not agree to an enhanced compensatory damage award, and the circuit court ordered a new trial on the basis that the verdict was against the weight of the evidence. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion in sustaining Employee's motion; and (2) the circuit court did not abuse its discretion in ordering a new trial on the issue of compensatory damages only. View "Badahman v. Catering St. Louis" on Justia Law

Respondent filed a declaration of candidacy to run for the position of Director of Community Fire Protection District (Community Fire). Community Fire accepted Respondent's declaration of candidacy, but Respondent was subsequently disqualified because his financial interest statement had not been timely filed. Fire Chief Charles Coyne filed a petition requesting the circuit court enter an order directing Respondent to show cause why his name should not be stricken from the ballot. The trial court ruled that Respondent was disqualified from running for the position and ordered that his name be removed from the ballot. The Supreme Court affirmed, holding that the trial court did not err in its judgment, as (1) Chief Coyne had capacity to bring this action on behalf of Community Fire, which had standing to bring the action; (2) Respondent received adequate notice of his obligation to file a financial interest statement; and (3) the statutory financial interest statement notice requirements are constitutionally valid. View "Coyne v. Edwards" on Justia Law

After a jury trial, Defendant was convicted of first-degree robbery, forcible rape, attempted forcible rape, and forcible sodomy. Defendant appealed, claiming (1) the trial court erred in admitting into evidence his incriminating statements to police because the statements were made involuntarily in reliance on an agreement the state failed to honor, and (2) there was insufficient evidence to support his conviction of two separate counts of first-degree robbery. The Supreme Court (1) vacated Defendant's for first-degree robbery as charged in the second count based on the state's concession Defendant was wrongfully subjected to multiple convictions for taking multiple items of property from the victim in the course of a single incident; and (2) affirmed the judgment in all other respects, holding that the trial court did not err in admitting Defendant's pretrial statements, as the facts clearly supported the trial court's finding that Defendant's statements were voluntary. View "State v. Hicks" on Justia Law

After a jury trial, Plaintiff was found guilty of first-degree murder and armed criminal action. The circuit court sentenced Defendant to death. The Supreme Court affirmed the judgment, holding (1) the trial court did not plainly err in its rulings regarding the jury and jury instructions; (2) the prosecutor did not engage in improper arguments or make improper comments; (3) the trial court did not err in its evidentiary rulings; (4) the trial court did not err in its rulings during the penalty phase; and (5) in this case, the death penalty complied with all statutorily proportionality requirements. View "State v. McFadden" on Justia Law

In 2010, the General Assembly enacted the Missouri Secure and Fair Enforcement Mortgage Licensing Act (Missouri SAFE Act), which provides that the director of the Missouri Division of Finance shall not issue a mortgage loan originator license to an applicant who has been convicted of or pleaded guilty to a felony within seven years prior to the date of the application. When Plaintiff subsequently submitted an application for a mortgage loan originator license, the director denied the license pursuant to the Act because Plaintiff had pleaded guilty to a felony in 2006. The circuit court entered a declaratory judgment finding that the Act was unconstitutional as applied to Plaintiff. The Supreme Court reversed, holding that, as applied to Plaintiff, the statute (1) was not an unconstitutional bill of attainder; (2) did not violate the Missouri Constitution's ban on retrospective laws; and (3) did not violate Plaintiff's right to procedural and substantive due process. View "Garozzo v. Mo. Dep't of Ins., Div. of Fin." on Justia Law

After a jury trial, Defendant was convicted of two counts of harassment, one under Mo. Rev. Stat. 565.090.1(2) and one under section 565.090.1(5), and one count of possession of marijuana. The harassment charges stemmed from emails Defendant sent to public officials that contained personally offensive language and references to sawed-off shotguns, assassinations, and domestic terrorism. The Supreme Court affirmed in part and reversed in part, holding (1) the content of Defendant's emails did not constitute protected speech, and therefore, section 565.090.1(2) was constitutional as applied to Defendant, and there was sufficient evidence to support his conviction on that count; and (2) the judgment as to the second count of harassment was set aside, as State v. Vaughn invalidated section 565.090.1(5), and manifest injustice would result if the conviction under that statute was not reversed. View "State v. Wooden" on Justia Law

After a jury trial, Defendant was convicted of murder, assault, burglary, and armed criminal action. Defendant subsequently filed a petition for writ of habeas corpus, petitioning the Supreme Court to vacate his convictions and to grant him a new trial because newly discovered evidence showed (1) the State violated Brady v. Maryland by withholding material, favorable evidence, and (2) the lack of disclosure of this Brady material was prejudicial. After a hearing, a special master found that the State had violated Brady in at least two important and material respects and that the State's failure to produce this Brady material was prejudicial. The Supreme Court concluded that substantial evidence supported the master's findings and, accordingly, ordered that Defendant's convictions be vacated and ordered him discharged from the custody of the department of corrections unless the State filed in the circuit court an election to retry him. View "State ex rel. Woodworth v. Denney" on Justia Law

Appellants, Father and Son, were arrested for driving while intoxicated during separate traffic stops. Preliminary breath tests showed Appellants' blood-alcohol contest to be over the legal limit. Father agreed to take a breathalyzer test but refused to provide sufficient breath to perform the test, and Son refused to take the breathalyzer test. The director of revenue revoked Appellants' driving privileges for one year. Appellants filed petitions for review, which the circuit court denied. Appellants appealed, asserting (1) the trial court violated their due process rights by admitting the director's records into evidence without providing them the opportunity to confront and cross-examine the director's witnesses who created the records; and (2) Mo. Rev. Stat. 302.312, which authorizes the admission of the director's records in evidence in court and administrative proceedings, is unconstitutional. The Supreme Court affirmed, holding that the provision of section 302.312 authorizing the admission of the director's records by the trial court did not deny Appellants their constitutional rights to confrontation and cross-examination, as Appellants had the right to subpoena witnesses to appear at the trials on their petitions for review. View "Doughty v. Dir. of Revenue" on Justia Law

Defendant pleaded guilty to three counts of statutory sodomy in the first degree. Before trial, a third amended information was filed that charged Defendant as a predatory sex offender on Counts I and III. A factual basis of Defendant's guilt and status as a predatory sex offender was established at the plea hearing. Defendant filed a motion for post-conviction relief, alleging (1) his constitutional right to a jury trial was denied when the circuit court overruled his motion challenging the trial court's determination of his classification as a predatory sexual offender under Mo. Rev. Stat. 558.018, and (2) his due process rights were violated when the trial court overruled his motion challenging the hearing classifying him as a predatory sexual offender under Mo. Rev. Stat. 558.021.2 before the commencement of the scheduled jury trial. The motion court overruled Defendant's post-conviction motion without an evidentiary hearing. The Supreme Court affirmed, holding that the motion court did not clearly err in determining Defendant waived his constitutional challenges when he pleaded guilty. View "Garris v. State" on Justia Law