In this case, petitioner Andre Taylor sought a writ of habeas corpus after pleading guilty to multiple drug trafficking counts and being sentenced to imprisonment with placement in a Long Term Drug Program (LTDP) under section 217.362, based on advice that he would serve only nine to eighteen months. The department of corrections later determined he was ineligible due to prior convictions for dangerous felonies, which neither the trial court nor his counsel had verified before sentencing as required by statute. Although Taylor did not file a timely Rule 24.035 motion, the court found cause for the procedural default because he was misled about eligibility and did not learn of the error until after the filing period, along with prejudice because he would not have accepted the plea if fully informed. The court vacated the sentences as unlawful, allowing Taylor to withdraw his guilty plea while remanding him to the department of corrections.
This case involved Lana C. Elrod's claim for workers' compensation benefits from Missouri's Second Injury Fund after a 1995 knee injury at work, which she argued combined with preexisting conditions like ankle injuries, obesity, and diabetes to cause greater disability. The Labor and Industrial Relations Commission awarded her permanent-partial disability benefits from the Fund but denied permanent-total disability. The Missouri Supreme Court affirmed, ruling that the claim against the Fund was timely under section 287.430 because it was filed within one year of an amended claim against the employer, and that sufficient evidence supported the partial disability finding while Elrod failed to prove total disability preventing any reasonable employment. The decision turned on statutory interpretation of the limitations period applying to any timely claim and factual review deferring to the Commission's credibility determinations on medical evidence.
The case involved Brent and Tonya Werremeyer who bought a used car from K.C. Auto Salvage Co. after the seller represented that the vehicle had not been rebuilt or wrecked and had clean title, despite a scratched vehicle identification number; the buyers later learned the car was assembled from a stolen vehicle and a wrecked one. They sued for common-law fraud and violation of a statute barring sale of vehicles with altered identification numbers, obtaining a jury verdict of $9,000 in compensatory damages and $20,000 in punitive damages. The trial court denied prejudgment interest, but on appeal the court affirmed liability and the punitive award, ruling that the evidence supported fraud, the statute imposes strict liability without a knowledge element, and the total judgment exceeded the buyers' settlement offer. The court reversed on prejudgment interest, holding that the governing statute allows interest on the entire judgment, including punitive damages, when a proper settlement offer is rejected.
John Wallingford filed a pro se motion for post-conviction relief under Rule 29.15 after his felony convictions were affirmed on appeal, but omitted his signature on the motion within the 90-day filing deadline, although he signed an accompanying in forma pauperis affidavit. The circuit court dismissed the motion for lack of jurisdiction, treating the missing signature as rendering it a nullity. The Missouri Supreme Court reversed, holding that Rule 55.03(a) applies to such motions and allows a party to promptly correct an omitted signature after it is called to their attention, whether the correction occurs within or after the original 90-day period. Wallingford had corrected the omission once it was discovered by counsel, satisfying the rule as interpreted in Tooley v. State. The case was remanded for further proceedings.
In State v. Pond, the defendant was charged with first-degree statutory sodomy and convicted after the trial court declined to instruct the jury on the lesser-included offense of first-degree child molestation. The Missouri Supreme Court reversed and remanded, holding that the lesser-included instruction was required because the evidence, including inconsistencies in the victim's testimony about whether penetration occurred, provided a basis for the jury to acquit on sodomy (which requires proof of penetration) while convicting on molestation (which requires only sexual contact). The court clarified that section 556.046.2 does not demand affirmative evidence from the defense to support a lesser-included instruction and overruled prior cases imposing such a requirement. It also upheld the trial court's finding that Pond qualified as a prior offender based on his earlier unconditional guilty plea.
This case concerns the proper venue for lawsuits against multiple nonprofit corporations under Missouri law. The Missouri Supreme Court held that when several nonprofit corporations are sued together and share common or joint liability, venue is proper in any location where it would be proper for at least one of them, such as the county of its principal place of business. The court reasoned that the venue statute for nonprofits, section 355.176.4, applies to multiple corporations by interpreting the singular to include the plural, and followed precedents allowing venue based on one defendant's location in cases of joint liability. This resolved disputes over whether suits against BJC Health System and affiliates could proceed in St. Louis City despite the underlying events occurring in St. Louis County.
