Justia Civil Procedure Opinion Summaries

James Eckardt, an aircraft mechanic, sustained multiple work-related injuries over his 40-year career, including injuries to his knees, shoulders, wrists, and cervical spine. His final injury occurred in October 2015, leading to a spinal fusion surgery. Eckardt retired in February 2017 due to his inability to perform his job duties and sought permanent total disability (PTD) benefits from the Treasurer of Missouri as Custodian of the Second Injury Fund.An administrative law judge (ALJ) in the Division of Workers’ Compensation assigned permanent partial disability (PPD) amounts to Eckardt’s preexisting injuries and determined he was permanently and totally disabled, awarding PTD benefits. The Fund appealed to the Labor and Industrial Relations Commission, arguing that the ALJ improperly considered non-qualifying injuries, including carpal tunnel syndrome and a right shoulder injury, in the PTD determination. The Commission reversed the ALJ’s decision, finding that the doctor’s reliance on the non-qualifying right shoulder injury meant there was no credible evidence that Eckardt was permanently and totally disabled due to the primary injury in combination with only qualifying preexisting injuries.The Supreme Court of Missouri reviewed the case and affirmed the Commission’s denial of PTD benefits. The Court held that Eckardt’s right shoulder injury did not qualify as a preexisting disability because it did not meet the statutory threshold of 50 weeks PPD, and a load factor could not be applied to enhance the PPD amount. The Court also found that Eckardt failed to show he was permanently and totally disabled due to the combination of his primary injury and only his qualifying preexisting disabilities, as the doctor’s opinion improperly included the non-qualifying right shoulder injury. Therefore, Eckardt did not meet his burden of proof for Fund liability, and his claim for PTD benefits was denied. View "Eckardt v. Treasurer" on Justia Law

Trent Berhow, while incarcerated at Western Missouri Correctional Center, fell from a ladder and subsequently filed a lawsuit against the state of Missouri, alleging that his supervisor's instructions created a dangerous condition leading to his injury. Berhow filed his suit more than a year after the incident, which brought into question the statute of limitations.Initially, Berhow sued the Missouri Department of Corrections. The department moved to dismiss the petition, citing the statute of limitations. Berhow then amended his petition to dismiss the department and add the state as the defendant. The Circuit Court of DeKalb County overruled the state's first motion for judgment on the pleadings but later sustained the state's renewed motion, which argued both sovereign immunity and the statute of limitations. Berhow's motion for sanctions was also effectively overruled by the circuit court.The Supreme Court of Missouri reviewed the case de novo. The court held that Berhow's claim was barred by the statute of limitations under section 516.145, which requires actions against the Department of Corrections or any entity thereof to be brought within one year. The court reasoned that allowing Berhow to sue the state instead of the department would defeat the purpose of the statute, as the department acts on the state's behalf. The court affirmed the circuit court's judgment, concluding that the statute of limitations barred Berhow's claim. View "Berhow v. State" on Justia Law

In 2015, the Missouri General Assembly enacted sections 67.287 and 479.359.2, which imposed certain standards and revenue caps on municipalities, specifically targeting St. Louis County. The City of Normandy and other municipalities challenged these statutes, claiming they violated the Missouri Constitution's prohibition against local or special laws. In 2016, the Circuit Court of Cole County declared these sections unconstitutional and issued a permanent injunction against their enforcement. The Missouri Supreme Court affirmed this decision in City of Normandy v. Greitens.Following a shift in legal analysis in City of Aurora v. Spectra Communications Group, LLC, the state sought relief from the 2016 injunction, arguing that the statutes would have survived under the new rational basis review. The circuit court initially granted this relief, but the Missouri Supreme Court vacated that judgment in City of Normandy v. Parson, remanding the case for further proceedings. On remand, the circuit court overruled the state's motion for partial relief from the judgment.The Missouri Supreme Court reviewed the case and affirmed the circuit court's decision. The court held that the change in legal analysis from City of Aurora did not automatically warrant relief from the permanent injunction under Rule 74.06(b)(5). The court emphasized the importance of finality in judgments and found that the state did not demonstrate sufficient inequity to justify lifting the injunction. The court also noted that the state had not sought relief from the declaratory judgment that the statutes were unconstitutional, which remained in effect. Therefore, the circuit court did not abuse its discretion in denying the state's motion for relief. View "City of Normandy v. Kehoe" on Justia Law

Ethel Barry Masters filed a petition against Jacob Dawson in 2019, alleging replevin, conversion, and unjust enrichment after Dawson refused to surrender possession of four vehicles that belonged to Masters' deceased long-term companion. Dawson disputed ownership and obstructed the legal process, including failing to respond to requests for admissions and barricading the vehicles to prevent towing. The circuit court granted partial summary judgment in favor of Masters, ordering Dawson to surrender the vehicles, which he did not comply with. Dawson's attorney withdrew due to ethical concerns, and subsequent attorneys also withdrew due to Dawson's failure to pay legal fees.The Circuit Court of St. Louis County scheduled multiple trial dates, which were postponed due to Dawson's actions, including retaining new attorneys and filing motions for continuance. Dawson failed to appear for a pretrial conference, leading the circuit court to cancel the jury trial and enter a default judgment in favor of Masters, awarding her $83,035.41 in actual damages and an equal amount in punitive damages. Dawson's conduct was deemed contemptuous, justifying punitive damages to deter similar behavior.The Supreme Court of Missouri reviewed the case and found that Dawson's constitutional claims regarding the right to a jury trial were unpreserved because he did not adequately raise them in his motion for a new trial. The court held that the circuit court did not abuse its discretion by sanctioning Dawson due to his pattern of obstructive behavior. The Supreme Court of Missouri affirmed the circuit court's judgment, upholding the damages awarded to Masters. View "Masters v. Dawson" on Justia Law

Great Plains Trucking Inc. and Lennis H. Beck (defendants) appealed a circuit court judgment in favor of Carrie S. Schultz and Robert C. Schultz, Sr. (plaintiffs), surviving parents of Robert C. Schultz, Jr., in a wrongful death action. Beck, a truck driver for Great Plains, collided with the plaintiffs' vehicle, resulting in the death of their son. The collision occurred in Wentzville, Missouri, under dark and rainy conditions. The plaintiffs' vehicle had fishtailed and was struck by another vehicle before Beck's truck collided with it.The Circuit Court of St. Charles County held a jury trial, which resulted in a verdict awarding the plaintiffs $10,000,000 in compensatory damages, $10,000,000 in aggravating circumstances damages against Great Plains, and $25,000 in aggravating circumstances damages against Beck. The circuit court entered judgment in accordance with the jury's verdicts and awarded post-judgment interest. The defendants filed a post-trial motion for a new trial or judgment notwithstanding the verdict, which the circuit court overruled. The defendants then appealed.The Supreme Court of Missouri reviewed the case and affirmed the circuit court's judgment. The court found that the defendants did not preserve their claims of error for appellate review or that their preserved claims failed on the merits. Specifically, the court held that the defendants failed to preserve the issue of excluding expert testimony regarding the mother's impairment by THC because they did not object at trial. Additionally, the court found that the defendants did not preserve their objection to the participation of separate counsel for the plaintiffs throughout the trial.The court also held that there was substantial evidence to support the jury's finding that Beck failed to keep a careful lookout and that the jury's award of aggravating circumstances damages against both Beck and Great Plains was supported by sufficient evidence. The court concluded that Beck's multiple violations of the Missouri CDL manual and Great Plains' acceptance of Beck's conduct demonstrated complete indifference or conscious disregard for the safety of others. View "Schultz vs. Great Plains Trucking, Inc." on Justia Law

Jeromy McCrackin filed a wrongful death action against Tynan Mullen for the death of McCrackin’s son, who was shot and killed outside a pool hall in 2019. Safeco Insurance Company of America had issued a homeowners insurance policy to Mullen’s grandmother, with whom Mullen allegedly lived at the time. Mullen was indicted for first-degree murder and armed criminal action but pleaded guilty to first-degree involuntary manslaughter and armed criminal action. McCrackin offered to settle the wrongful death claim against Mullen in exchange for Safeco’s agreement to pay the total liability coverage limits, which Safeco declined, stating the policy excluded coverage for intentional acts.The Circuit Court of Jackson County overruled Safeco’s motion to intervene in the wrongful death action for the purpose of seeking a stay until a separate federal declaratory judgment action could be resolved. Safeco had filed the federal action to determine whether it had a duty to defend or indemnify Mullen. The circuit court held a bench trial in the wrongful death action, overruled Safeco’s motion to intervene, and entered a judgment against Mullen, awarding McCrackin $16.5 million in damages.The Supreme Court of Missouri reviewed the case and held that Safeco had a right to intervene in the wrongful death action pursuant to Rule 52.12(a)(2) for the limited purpose of seeking a stay. The court found that Safeco had an interest in the wrongful death action and that the disposition of the action could impair or impede its ability to protect that interest. The court vacated the circuit court’s judgment and remanded the case for further proceedings consistent with its opinion. The court did not direct how the circuit court should rule on the motion to stay, leaving that decision to the lower court. View "McCrackin vs. Mullen" on Justia Law

Joe David Hudson was injured while working for Joplin Regional Stockyards, Inc. (JRS) in 2002. In 2005, Hudson, JRS, and JRS' insurer, Star Insurance Company, entered into a settlement agreement where Hudson received an $80,000 lump sum. The settlement left future medical expenses for Hudson's left ankle open. In 2011, Hudson had a below-the-knee amputation, which Star refused to cover. Hudson filed the settlement in circuit court in 2013, and the court rendered judgment in accordance with the settlement. Hudson later filed an equitable garnishment action, leading Star to pay $92,000 for his medical bills. In 2015, Star agreed to reimburse Hudson up to $610,311.75 for future medical expenses. In 2016, Hudson and JRS entered into a subordination agreement, acknowledging all payments due under the judgment had been received.In 2022, Hudson filed a motion to revive the judgment, which JRS opposed, arguing the judgment had been satisfied and the Division of Workers' Compensation had not determined the future medical care provision. JRS also filed a motion for relief from the judgment, claiming it was void due to lack of due process. The Circuit Court of Jasper County sustained Hudson's motion to revive the judgment and overruled JRS' motion for relief.The Supreme Court of Missouri reviewed the case and determined that JRS had standing to appeal. The court found that the circuit court erred in reviving the judgment because JRS had satisfied the judgment by paying the $80,000 lump sum. The court reversed the circuit court's order sustaining Hudson's motion to revive the judgment and overruled Hudson's motion to revive the judgment. Hudson's motion for damages for a frivolous appeal was also overruled. View "Hudson v. Joplin Regional Stockyards, Inc." on Justia Law

Jessica Goodman, the Saline County Assessor, filed a lawsuit seeking a declaration regarding the correct classification of Saline County under Missouri law. Goodman argued that Saline County should be classified as a third-class county based on its assessed valuation over five years, rather than its current classification as a second-class county. The County moved to dismiss the petition, arguing that the statute in question, section 48.020.1, exempts Saline County from reclassification regardless of changes in assessed valuation.The Circuit Court of Saline County dismissed Goodman’s petition. Goodman appealed the decision to the Missouri Court of Appeals, Western District. The Court of Appeals transferred the case to the Supreme Court of Missouri, believing that the case involved the validity of a state statute, which would fall under the Supreme Court's exclusive jurisdiction.The Supreme Court of Missouri determined that it did not have exclusive appellate jurisdiction because Goodman did not properly raise a constitutional challenge to the statute in question. Goodman’s arguments against the County’s interpretation of the statute did not amount to a direct claim that the statute was unconstitutional. As a result, the Supreme Court of Missouri retransferred the case back to the Missouri Court of Appeals, Western District, for further proceedings. View "Goodman vs. Saline County Commission" on Justia Law

The case revolves around Benjamin Ramirez, who, on behalf of a putative class, sued the Director and the Treasurer of the Missouri Department of Revenue in their official capacities. Ramirez had resolved criminal charges against him by pleading guilty and paying court costs, including certain mandatory surcharges. These surcharges were then paid to various funds, as authorized by Missouri statute. Ramirez alleged that the Director and the Treasurer received payment of, collected, and deposited the surcharges in and otherwise managed these funds. He claimed a single count of unjust enrichment and asserted the statutes authorizing the surcharges violate a section of the Missouri Constitution.The Director and the Treasurer moved for summary judgment, asserting that Ramirez’s suit is barred by sovereign immunity and the statutes authorizing the surcharges do not violate the Missouri Constitution. The circuit court sustained the motion, concluding the statutes authorizing the surcharges do not violate the Missouri Constitution. Ramirez appealed this decision.The Supreme Court of Missouri affirmed the circuit court's judgment. The court held that sovereign immunity, a common law judicial doctrine barring suit against a government or public entity, applied to Ramirez's claim for unjust enrichment. The court noted that sovereign immunity is the default rule in all suits against the state and applies to non-tort claims. The court found that the state had not waived its sovereign immunity through express statutory consent or a recognized common law exception. Therefore, Ramirez's unjust enrichment suit against the Director and the Treasurer was barred by sovereign immunity. View "Ramirez vs. Missouri Prosecuting Attorneys' & Circuit Attorneys' Retirement System" on Justia Law

The case involves a group of appellants, collectively referred to as "Challengers", who appealed judgments declaring section 67.1175.1 of the Missouri Statutes constitutionally invalid. This provision, in conjunction with section 67.1177, required a political subdivision to grant public money to a private entity, which was deemed to violate article VI, section 23 of the Missouri Constitution. The circuit court attempted to rectify the constitutional invalidity by modifying section 67.1175.1. The Challengers, however, argued that despite the modification, the sections still required a political subdivision to grant public money to a private entity in violation of the constitution. They further argued that the entire statutory scheme must be struck down because the sections were not severable.The circuit court had declared section 67.1175.1 constitutionally invalid because it mandated the lake area business districts to transfer tax funds to the advisory board, a private nonprofit entity. The court modified the section by removing the phrase "which shall be a nonprofit entity". The Challengers appealed this decision, arguing that the modified sections still violated the constitution.The Supreme Court of Missouri found that the circuit court erred in modifying section 67.1175.1. The court concluded that the section, as modified, and section 67.1177, still required political subdivisions to grant public money to a private entity, violating the Missouri Constitution. The court also concluded that the void provisions were not severable from the remaining provisions of the statutory scheme. As a result, the entire statutory scheme was declared constitutionally invalid. The circuit court’s judgment was reversed, and the Supreme Court entered the judgment the circuit court should have entered, declaring sections 67.1170, 67.1175, 67.1177, and 67.1170 constitutionally invalid and void in their entireties. View "Salamun v. The Camden County Clerk" on Justia Law