Justia Civil Procedure Opinion Summaries

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

David Steele filed a lawsuit against his employer, Johnson Controls, Inc. (JCI), alleging that the company had violated § 287.780 by retaliating and discriminating against him for filing a workers' compensation claim. Steele sought compensatory and punitive damages, arguing that JCI had acted with willful, deliberate, and reckless disregard for his rights. JCI did not file an answer or responsive pleading, and Steele subsequently filed a motion for default judgment and damages. The circuit court held a hearing regarding damages, during which Steele testified about his injuries and the discriminatory treatment he received from JCI. The court entered a default judgment for Steele, awarding him $300,000 in compensatory damages and $600,000 in punitive damages.JCI filed a motion to set aside the default judgment, citing Rules 75.01, 74.05(d), and 74.06(b)(1). JCI alleged that it had good cause for the default because its registered agent mislabeled the service documents and routed them to the incorrect section of JCI's legal department. The circuit court held a hearing on JCI's motion and subsequently overruled it, concluding that JCI failed to show good cause, a meritorious defense, or excusable neglect. JCI then filed a motion for a new trial, which the circuit court also overruled. JCI appealed the decision.The Supreme Court of Missouri affirmed the circuit court's judgment. The court found that JCI had failed to prove good cause for its default as required to set aside the default judgment pursuant to Rule 74.05(d). The court also found that JCI's reliance on Rules 75.01 and 74.06(b)(1) as alternate bases to set aside the default judgment was incorrect. Finally, the court ruled that JCI's defaulted claims asserting the circuit court plainly erred by awarding punitive damages in violation of § 510.2612 were not reviewable. View "Steele v. Johnson Controls, Inc." on Justia Law

In this case, Quinton Lucas, a registered voter, challenged the approval of Amendment No. 4 in the November 2022 general election. The amendment authorized laws that increased minimum funding for a police force established by a state board of police commissioners. Lucas claimed that the fiscal note summary printed on every ballot cast in the election materially misstated the fiscal note for the measure.The Supreme Court of Missouri, which was reviewing the case, had previously overruled the state's motion to dismiss Lucas' claim. The state had argued that Lucas' contest was time-barred, that the city lacked standing as a voter, and that the statutes providing remedies if an election contest succeeds were unconstitutional.The Supreme Court of Missouri found that the fiscal note summary was both materially inaccurate and seriously misleading. The court held that this constituted an "irregularity" of sufficient magnitude to cast doubt on the validity of the election. As a result, the court ordered a new election on the question to be conducted as part of the statewide general election on November 5, 2024. View "Lucas vs. Ashcroft" on Justia Law

The plaintiff, Yarnell, filed a wrongful death action against Clinton No. 1, Inc., a healthcare and rehabilitation center, alleging that Clinton's negligence led to her mother's death from COVID-19. The Missouri Supreme Court addressed whether Clinton's proposed theories of immunity barred Yarnell's claims, which were based on the Public Readiness and Emergency Preparedness (PREP) Act and two Missouri acts.Yarnell's mother had contracted with Clinton for a private room, but Clinton placed her with a roommate, which Yarnell claimed exposed her mother to COVID-19, violated their agreement, and ultimately led to her mother's death. Clinton argued that Yarnell's claims were barred by the PREP Act, which provides immunity for healthcare providers administering or using covered countermeasures during a public health emergency, and Missouri laws granting immunity to healthcare providers during an emergency declared by the governor and in COVID-19 exposure actions.The court found that Yarnell's petition did not implicate a covered countermeasure under the PREP Act, as it made no reference to the administration or use of a diagnostic test or any other covered countermeasure. The court also found that Clinton failed to demonstrate it agreed to be deployed during the emergency or that the governor or any state agency acted on such agreement and deployed Clinton, which would have entitled it to immunity under Missouri law. Lastly, the court noted that Yarnell had adequately alleged her harm was caused by Clinton's recklessness, and the two COVID-19 statutes would not foreclose relief if Yarnell were able to prove such recklessness. Therefore, the court quashed its preliminary writ of mandamus, allowing Yarnell's case to proceed. View "State ex rel. Clinton No. 1 vs. Baker" on Justia Law

In 2012, Dane Templeton suffered an injury to his right knee and thigh after being thrown from a golf cart. Dr. Charles Orth operated on Templeton’s injured leg and provided follow-up care for several months. In 2015, Templeton returned to Dr. Orth due to swelling in his knee, prompting another surgery and more follow-up care that lasted until August 2016. However, Templeton decided to seek a second opinion from Dr. Michael Tilley in September 2016. After receiving an alternative treatment plan from Dr. Tilley, Templeton decided to follow this new plan and stopped taking the antibiotics prescribed by Dr. Orth. On October 9, 2018, Templeton filed a lawsuit against Dr. Orth for medical malpractice, alleging negligence in his treatment.Dr. Orth sought summary judgment, arguing that the lawsuit was barred by the two-year statute of limitations. According to Dr. Orth, Templeton ended the physician-patient relationship when he sought treatment from Dr. Tilley without following up with Dr. Orth. The circuit court agreed with Dr. Orth, concluding that the lawsuit was indeed barred by the statute of limitations. Templeton appealed this decision, arguing that the continuing care doctrine should have tolled the statute of limitations.The Supreme Court of Missouri affirmed the circuit court's judgment. The Supreme Court determined that Templeton had actively ended the continuing care relationship with Dr. Orth when he chose to follow Dr. Tilley's treatment plan and stopped taking the antibiotics prescribed by Dr. Orth. As such, Templeton's lawsuit, filed more than two years after ending the physician-patient relationship, was barred by the statute of limitations. The Court clarified that the continuing care doctrine did not apply because the relationship had ended before the necessity for treatment had ceased. View "Templeton vs. Orth" on Justia Law