Justia Civil Rights Opinion Summaries

The Supreme Court made permanent preliminary writs of prohibition sought by Relators to prevent the circuit court from taking any action other than vacating its orders overruling their respective motions to dismiss on the grounds that Plaintiff’s Missouri Human Rights Act (MHRA) claims against them for discrimination and retaliation were time barred.After Relators each filed a motion to dismiss as time barred Alicia Mulvey’s MHRA claims for discrimination and retaliation, Mulvey filed a motion for leave to amend her petition to include common law claims of negligence and wrongful discharge. The circuit court overruled Relators’ motions to dismiss and sustained Mulvey’s motion for leave to amend. The Supreme Court held that the circuit court exceeded its authority when it overruled Relators’ motions to dismiss for failure to state a claim and abused its discretion when it sustained Mulvey’s motion for leave to amend her petition because Mulvey failed to file her MHRA claim within the ninety-day statutory period and her common law claims of negligence and wrongful discharge were fully encompassed and comprehended by the MHRA. View "State ex rel. Church & Dwight Co. v. Honorable William B. Collins" on Justia Law

The Supreme Court affirmed the motion court’s judgment denying Appellant postconviction relief on his twelve claims of ineffective assistance of trial counsel, two claims of ineffective assistance of appellate counsel, and claims challenging the constitutional validity of Mo. Rev. Stat. 562.076 regarding voluntary intoxication and the time limits. Appellant filed his motion under Mo. R. Crim. P. 29.15. In affirming, the Supreme Court held (1) the motion court’s findings of fact and conclusions of law were not clearly erroneous; and (2) the motion court’s judgment regarding an unpreserved claim of error was not plainly erroneous. View "Collings v. State" on Justia Law

The circuit court did not err in sustaining Defendants’ motions to suppress all evidence seized pursuant to warrant authorizing search of a residence for stolen items.On appeal, the State argued that, while no probable cause existed for a provision of the search warrant form authorizing a search for any deceased human fetus or corpse, the circuit court should have applied the severance doctrine to redact the invalid portion of the warrant and suppress only the evidence seized pursuant to the invalid portion. The Supreme Court disagreed, holding that the circuit court did not err in refusing to apply the severance doctrine and in suppressing all evidence seized because the invalid portions of the search warrant so contaminated the whole warrant that they could not be redacted pursuant to the severance doctrine. View "State v. Gaulter" on Justia Law

The Supreme Court granted a writ of prohibition sought by Bayer Corporation and related entities (collectively, Bayer) directing the circuit court to dismiss nonresident Plaintiffs’ claims in a petition alleging personal injures from Essure, a female contraceptive device Bayer manufactures and distributes. Specifically, Bayer alleged that Missouri had no specific personal jurisdiction over eighty-five out of ninety-two plaintiffs, who were nonresidents of Missouri and did not allege that their injury occurred in Missouri. The Supreme Court vacated the circuit court’s order overruling Bayer’s motion to dismiss, holding that the petition did not assert any recognized basis for personal jurisdiction over Bayer with respect to nonresident Plaintiffs. View "State ex rel. Bayer Corp. v. Honorable Joan L. Moriarty" on Justia Law

The Supreme Court affirmed the circuit court judgments denying two employers’ requests for permanent writs of mandamus against the Missouri Commission on Human Rights (MCHR). The circuit court rejected Employers’ arguments that the MCHR was required to first determine whether Employers’ employees’ complaints of discrimination were timely filed with the MCHR before the MCHR had authority to issue the employees a right-to-sue letter. The Supreme Court held (1) Mo. Rev. Stat. 213.111.1 requires the MCHR to issue a right-to-sue letter and terminate all proceedings related to a complaint if 180 days have elapsed and the employee has made written request for a right-to-sue letter; and (2) because that is what occurred in both of these cases, the MCHR was required to issue the right-to-sue letters, and the circuit court properly refused to issue writs directing the MCHR to perform an act the MHRA prohibits. View "State ex rel. Tivol Plaza, Inc. v. Missouri Commission on Human Rights" on Justia Law

In 1983, Carr was convicted capital murder for killing his brother, stepmother, and stepsister when he was 16 years old. He was sentenced to three concurrent terms of life in prison without the possibility of parole for 50 years. His sentences were imposed without any consideration of his youth. The Missouri Supreme Court granted his petition for a writ of habeas corpus. His sentences violate the Eighth Amendment because, following the Supreme Court’s 2012 decision in Miller v. Alabama, juvenile offenders cannot be sentenced to life without parole pursuant to mandatory sentencing schemes that preclude consideration of the offender’s youth and attendant circumstances. Carr was sentenced under a mandatory sentencing scheme that afforded no opportunity to consider his age, maturity, limited control over his environment, the transient characteristics attendant to youth, or his capacity for rehabilitation. Carr must be resentenced so his youth and other attendant circumstances surrounding his offense can be taken into consideration to ensure he will not be forced to serve a disproportionate sentence in violation of the Eighth Amendment. View "Carr v. Wallace" on Justia Law

After a jury trial, Appellant was convicted of two counts of murder in the first degree for shooting and killing two deputies. Appellant was sentenced to death. Appellant’s convictions were affirmed on direct appeal. Thereafter, the motion court granted Appellant post-conviction relief and remanded the case for a new penalty phase. After the penalty phase retrial, the jury recommended that Appellant be sentenced to death on each count. The trial court sentenced Appellant in accordance with the jury’s recommendation. Appellant’s death sentences were affirmed on direct appeal. Appellant then filed a Mo. R. Crim. P. motion for post-conviction relief, alleging several claims of ineffective assistance of trial and appellate counsel. The motion court overruled the motion. The Supreme Court affirmed, holding that the motion court did not clearly err in finding that Appellant failed to establish that he was provided ineffective assistance of trial or appellate counsel. View "Tisius v. State" on Justia Law

When William Fleming failed to pay his court costs within the first three years of his probation, Fleming’s probation was revoked and execution of his concurrent seven-year sentences was ordered. Fleming filed a petition for writ of habeas corpus, arguing that the sentencing court violated his due process and equal protection rights by revoking his probation solely because he was indigent. The Supreme Court issued a writ of habeas corpus, holding that the sentencing court’s revocation of Fleming’s probation violated Fleming’s Fourteenth Amendment rights because the court failed to inquire into the reasons for Fleming’s failure to pay his court costs. View "State ex rel. Fleming v. Missouri Board of Probation & Parole" 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

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