Justia Government & Administrative Law Opinion Summaries

Articles Posted in Supreme Court of Missouri
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The Supreme Court vacated the decision of the Administrative Hearing Commission (AHC) that the purchases by Carfax, Inc. of certain equipment used to create vehicle history reports (VHRs) were exempt from sales and use taxes under Mo. Rev. Stat. 144.030.2(5) and 144.054.2 because Carfax used such equipment to "manufacture" VHRs, holding that Carfax did not use the equipment in the "manufacturing" of its VHRs.After an audit, the Director of Revenue determined that Carfax did not use the disputed equipment to manufacture VHRs, and therefore, its purchase of that equipment was not exempt from sales and use taxes. On appeal, the AHC found that Carfax's purchases of the equipment were exempt from sales and use taxes under both sections 144.303.2(5) and 144.054(2) because Carfax used that equipment directly in manufacturing VHRs. The Supreme Court vacated the decision below, holding that, for purposes of these statutes, Carfax did not use the disputed equipment to manufacture VHRs. View "Carfax, Inc. v. Director of Revenue" on Justia Law

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The Supreme Court reversed the judgment of the circuit court issuing a permanent writ of mandamus in favor of Jim Swoboda, holding that the circuit court's decision was erroneous because Swoboda failed to establish that he was entitled to mandamus relief.Swoboda filed a charge of discrimination with the Missouri Commission on Human Rights against his employer and Armstrong Teasdale, LLP (the Law Firm), alleging retaliation, disability, and aiding and abetting as types of discrimination he faced in retaliation for participating in a discrimination case brought by another officer. The Commission determined that it lacked jurisdiction over the matter because there was no employer-employee relationship between Swoboda and the Law Firm. The circuit court issued a writ of mandamus finding that the Commission erred in dismissing the charge without first taking certain steps. The Supreme Court reversed, holding that the issuance of mandamus relief was foreclosed where, rather than seeking to enforce a previously delineated right, Swoboda attempted to adjudicate whether his claim was permissible under applicable statutes. View "State ex rel. Swoboda v. Missouri Commission on Human Rights" on Justia Law

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The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission denying Claimant's claim for permanent total disability (PTD) benefits from the Second Injury Fund, holding that the Commission appropriately found that Claimant was not permanently and totally disabled.Claimant filed an amended workers' compensation claim against Employer, alleging that his primary work-related injuries were "bilateral upper extremities" and asserting a claim against the Fund for PTD benefits due to a prior injury to his bilateral lower extremities. An administrative law judge denied PTD benefits, and the Commission affirmed. The Supreme Court affirmed, holding that Claimant failed to carry his burden of persuasion in demonstrating that he was entitled to PTD benefits. View "March v. Treasurer of Missouri" on Justia Law

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The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission reversing the administrative law judge's (ALJ) award of permanent and total disability (PTD) benefits against the Second Injury Fund, holding that the Commission's findings were supported by substantial and competent evidence.Christopher Klecka suffered a compensable work-related injury to his left shoulder. After settling the primary claim with his employer Klecka brought a claim against the Fund, alleging that his primary injury combined with his prior injuries rendered him permanently and totally disabled (PTD). An ALJ issued an award against the fund for PTD benefits. The Commission reversed. The Supreme Court affirmed, holding that Klecka failed to establish that his primary injury and sole qualifying preexisting disability entitled him to PTD benefits from the Fund under Mo. Rev. Stat. 287.220.3. View "Klecka v. Treasurer of Missouri" on Justia Law

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The Supreme Court dismissed this appeal from the decision of the Labor and Industrial Relations Commission (Commission) reversing the administrative law judge's award and denying Claimant permanent total disability benefits, holding that Claimant's brief preserved nothing for appellate review because it failed to comply with the mandatory and straightforward rules governing the contents of an appellant's briefs.After the Commission denied Claimant's claim, Claimant appealed. The Supreme Court dismissed the appeal, holding that each of Claimant's points on appeal was defective because each point relied on wholly failed to follow the simple template provided in Rule 84.04. View "Lexow v. Boeing Co." on Justia Law

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The Supreme Court affirmed the judgment of the circuit court denying the petition for a permanent writ of prohibition filed by the Missouri Department of Health and Senior Services, holding that the circuit court did not err in denying the writ.After the Department denied the applications filed by Kings Garden Midwest LLC seeking two medical marijuana cultivation facility licenses Kings Garden requested that the Department provide complete and unreacted copies of successful cultivation license applications in discovery. The administrative hearing commission (AHC) granted the motion to compel. The Department filed a petition for a writ of prohibition seeking to bar enforcement of the AHC's order. The circuit court denied the writ. The Supreme Court affirmed, holding that because the plain language of allows confidential information to be used for purposes of appealing the Department's decision to deny a license, the AHC did not err in sustaining Kings Garden's motion to compel. View "State ex rel. Department of Health & Senior Services v. Slusher" on Justia Law

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The Supreme Court affirmed the decision of the Judicial Finance Commission (JFC) dismissing the Board of Commissioners of Franklin County's petition for review disputing whether the statutory maintenance of effort (MOE) operated as a statutory cap on its obligation to fund the Twentieth Judicial Circuit Court's Juvenile Division, holding that there was no error.When the Franklin County Commission and a judge of the Twentieth Circuit met to discuss the 2021 budget, the parties could not agree whether Franklin County would provide only the statutorily required MOE funding for the Juvenile Division. The Commission filed a petition for review with the JFC seeking a declaration that it would be not compelled to allocate and pay more than the MOE funding for the Juvenile Division. The JFC dismissed the action. The Supreme Court affirmed, holding that the JFC did not err in dismissing the Commission's petition for review. View "Board of Commissioners of County of Franklin v. Twentieth Judicial Circuit" on Justia Law

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The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission finding that Defendant was not entitled to an award of workers' compensation benefits because his injury did not arise out of and in the course of his employment, holding that there was no error.Defendant, a field service specialist for DISH Network, Inc,. was an a car accident after he choked on a sandwich and blacked out while traveling to his first appointment. Defendant sought workers' compensation benefits. The ALJ awarded benefits, but the Commission denied compensation because Defendant failed to prove his injury arose out of and in the course of his employment. The Supreme Court affirmed, holding that Defendant failed to establish that his injury arose out of and in the course of his employment. View "Boothe v. DISH Network, Inc." on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of the circuit court dismissing Petitioner's petition for declaratory judgment for failure to state a claim upon which relief can be granted, holding that the circuit court improperly dismissed Petitioner's claim with prejudice.In his petition, Petitioner sought a declaration that his federal supplemental security income was exempt under federal law from paying the required monthly intervention fees to the Missouri Department of Corrections, Division of Probation and Parole, as a condition of his supervised probation. The circuit court dismissed the petition with prejudice. The Supreme Court reversed in part, holding (1) Petitioner's request for declaratory relief was not ripe for adjudication; but (2) because Petitioner may be able to state a claim ripe for adjudication in the future, the circuit court improperly dismissed the claim with prejudice. View "Graves v. Missouri Department of Corrections" on Justia Law

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The Supreme Court affirmed the judgment declaring that the Honorable Patrick S. Flynn did not have authority, as the presiding judge of the 45th Judicial Circuit, to suspend Karla Allsberry, the circuit clerk of Lincoln County within the 45th Judicial Circuit, holding that the circuit court erred.At issue was whether Judge Flynn had the power under his general administrative authority as the presiding judge to suspend Allsberry, an elected circuit clerk, when the suspension was indefinite and had the effect of removing her from office, and whether the court had the authority to grant Allsberry injunctive relief. The Supreme Court held (1) the presiding judge is not authorized to take any action that has the practical effect of removing an elected circuit clerk from office; and (2) the circuit court erred in concluding that one circuit judge cannot order injunctive relief against another circuit judge. View "Allsberry v. Flynn" on Justia Law