Justia Government & Administrative Law Opinion Summaries

The Supreme Court of Missouri ruled in favor of three employees of a medical facility, Jayla Ruiz Morales, John Kimani, and Valarie Johnson, who were sued for wrongful death by the legal guardian of a patient, Ronald Scheer. Scheer, a resident at the St. Louis Developmental Disabilities Treatment Center-St. Charles Habilitation Center, died after his wheelchair's belt constricted his breathing. The employees were accused of failing to adequately supervise Scheer, failing to ensure that his wheelchair's seatbelt and pelvic harness were properly fastened, among other allegations. The employees argued that they were entitled to official immunity, a doctrine that protects public officials from liability for acts of negligence committed during the course of their official duties. The lower court rejected this argument and the employees sought a writ of prohibition from the Supreme Court of Missouri.The Supreme Court of Missouri held that the employees were entitled to official immunity. The court found that the tasks they were required to perform were not ministerial (routine or mundane tasks) but required discretion. Tasks such as checking on the patient, repositioning him, and using a seat belt and pelvic harness required the employees to use judgment to determine if Scheer needed additional care, and if so, what care to be administered. Therefore, these tasks were not ministerial and the employees were entitled to official immunity. The court made its preliminary writ of prohibition permanent, barring the lower court from taking further action in the case. View "State ex rel. Jayla Ruiz-Morales v. Alessi" on Justia Law

In Missouri, Jackson County and its public officials sought a writ of mandamus to overturn a circuit court's order which had denied their motion to dismiss a lawsuit brought by Jackson County property owners. The property owners alleged that the County had unlawfully increased assessed property values by failing to provide timely notice of increases and not conducting physical inspections for properties with increases of over 15%. The County argued that the property owners should have exhausted all available administrative remedies before filing the lawsuit.The Supreme Court of Missouri agreed with the County's argument, stating that the doctrine of exhaustion of administrative remedies requires an aggrieved party to seek available administrative remedies before courts will act. The court found that the County's failure to provide timely notice did not prevent the property owners from pursuing administrative remedies. At the time they filed the lawsuit, they could have exercised their appellate rights to the County's Board of Equalization or the State Tax Commission, but they chose not to. Therefore, the Supreme Court of Missouri held that because the property owners failed to exhaust all available administrative remedies before filing the lawsuit, the action must be dismissed, making permanent its preliminary writ of mandamus. View "State ex rel. Jackson County, Missouri v. Chamberlain" on Justia Law

The Supreme Court affirmed the final award of the labor and industrial relations commission affirming and adopting an administrative law judge's award of permanent total disability benefits to Jannie Harper under the Missouri Workers' Compensation Law, holding that the commission's decision was supported by competent and substantial evidence.Harper filed a claim for workers compensation against Springfield Rehab and Health Center and Premier Group Insurance Company Corvel Enterprise Company (collectively, Springfield Rehab). The commission awarded Harper permanent and total disability benefits, finding that Harper suffered a compensable injury arising from a workplace accident. The Supreme Court affirmed, holding that competent and substantial evidence supported the commission's final award of permanent total disability compensation and future medical care. View "Harper v. Springfield Rehab & Health Care Center" on Justia Law

The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission finding that Maryann Gray's applications for review were timely filed pursuant to Mo. Rev. Stat. 287.480 and overruling Hawthorn Children's Psychiatric Hospital's motion to strike, holding that the Commission did not err in finding that Gray's applications were timely filed.Gray, a registered nurse at Hawthorn, filed applications for review of the denial of her claims for injuries sustained during her employment. After a hearing, the Commission found Gray timely filed her applications and affirmed the denial of benefits as to a 2012 injury but ordered Hawthorn to pay Gray partial permanent disability benefits for 2013 and 2014 injuries. The Supreme Court affirmed, holding that the Commission did not err in finding that Gray's applications were timely filed under section 287.480. View "Gray v. Hawthorn Children's Psychiatric Hospital" on Justia Law

The Supreme Court affirmed the decision of the Administrative Hearing Commission determining that Walmart Starco LLC was exempt from use tax for its purchase and use of information technology equipment pursuant to Mo. Rev. Stat. 144.018.1 and 144.615(6), holding that the Commission correctly concluded that the equipment was exempt from use tax.The Commission ultimately determined that Starco's use of the information technology equipment at issue was exempt from use tax under sections 144.018.1 and 144.615(6). The Supreme Court affirmed, holding (1) Starco showed that it held the equipment solely for resale pursuant to section 144.615(6); and (2) the second argument raised on appeal was unpreserved for appellate review. View "Walmart Starco LLC v. Director of Revenue" on Justia Law

In this declaratory judgment action, the Supreme Court vacated the judgment of the circuit court overruling the motion to intervene as a matter of right filed by St. Louis and Jackson counties (the Counties), holding that the circuit court erred in overruling the Counties' motion to intervene as a matter of right.Plaintiffs brought this suit against the Department of Health and Senior Services. The circuit court ultimately declared that 19 C.S.R. 20-20.050(3) was constitutionally invalid. Several entities filed motions to intervene, including the Counties. The circuit court overruled all motions to intervene. The Supreme Court vacated the order below, holding that the circuit court erred in denying intervention where the motions were timely filed, the counties had an interest in the subject matter of the action, disposition of the action would impede their interests, and the existing parties no longer adequately represented their interest. View "Robinson v. Mo. Dep't of Health & Senior Services" on Justia Law

The Supreme Court affirmed the judgment of the circuit court making permanent a writ of mandamus ordering Attorney General Andrew Bailey to approve fiscal note summaries for eleven proposed initiative petitions Dr. Anna Fitz-James had filed with Secretary of State John Ashcroft and to forward notice of that approval to State Auditor Scott Fitzpatrick, holding that there was no error.Specifically, the Supreme Court held (1) nothing in Mo. Rev. Stat. 116.175 gives the Attorney General authority to question the Auditor's assessment of the fiscal impact of a proposed petition, and the Attorney General's authority extends only to reviewing the "legal content and form" of the fiscal notes and summaries prepared by the Auditor; (2) the circuit court properly found there was no defect in the legal form and content of the fiscal note summaries prepared by the Auditor concerning the proposed initiative petitions; and (3) therefore, the Attorney General's refusal to perform the duty of approving those summaries could not be justified. View "State ex rel. Fitz-James v. Bailey" on Justia Law

The Supreme Court reversed the decision of the Missouri Mining Commission awarding attorney fees and expenses in favor of Fowler Land Company and the Margaret Leist Revocable Trust (collectively, Landowners) after Landowners prevailed in litigation concerning the creation of water impoundments on their property, holding that the Commission erred in awarding fees and expenses.Alternative Fuels, Inc. (AFI) leased land from Landowners, who consented to AFI's creation of water impoundments on their property, but AFI constructed additional impoundments without consent. Missouri Department of Natural Resources (DNR) initiated enforcement actions against AFI, after which AFI received approval for a permit revision. The Commission upheld the approval. The circuit court reversed. On remand, the Commission denied the permit revision application. Thereafter, Landowners filed an application for attorney fees and expenses arguing that they were the prevailing party and were entitled to attorney fees. The Commission granted the application. The Supreme Court reversed, holding that Landowners' fee application was untimely, and therefore, the Commission erred in awarding Landowners attorney fees and expenses. View "State ex rel. Dep't of Natural Resources v. Fowler Land Co." on Justia Law

The Supreme Court affirmed the judgment of the circuit court, holding that the Missouri Constitution does not permit the General Assembly to limit the Conservation Commission's authority to expend and use conservation funds for constitutionally-enumerated purposes.The General Assembly enacted House Bill No. 2019 in 2020, appropriating $21 million to the Conservation Commission. The General Assembly, however, removed language from HB 2019 regarding use of the Commission's funds, including for land acquisition and payments in lieu of taxes (PILT). Later, the Commission attempted to withdraw funds to pay for a land acquisition and for PILT, but the Office of Administration denied the requests. The Commission and the Missouri Department of Conservation brought this action against the Attorney General and the Commissioner of the Office of Administration seeking declaratory relief to require certification of PILT payments. The circuit court ordered the Commissioner to certify the land purchase and PILT payments as requested. The Supreme Court affirmed, holding that, in passing HB 2019, the General Assembly invaded the Commission's constitutional authority by attempting to limit the constitutionally-enumerated purposes for which the Commission could use its funds. View "Conservation Comm'n v. Bailey" on Justia Law

The Supreme Court issued a writ prohibiting the Honorable Steven A. Judge Privette from proceeding in the underlying proceeding initiated against Betty Grooms, the circuit clerk of Oregon County, for contempt of court, holding that Judge Privette lacked authority to hold Grooms in contempt for alleged deficiencies in complying with the court order at issue.The subject court order directed Groom to prepare a spreadsheet of court costs assessed in criminal cases after local sheriff departments alleged that they had not received reimbursement for costs incurred incarcerating individuals in their county jails. Judge Privette subsequently ordered Grooms to show cause why she should not be held in contempt of court. The Supreme Court granted a writ of prohibition requested by Grooms, holding that Judge Privette lacked authority to hold Grooms in contempt for her alleged deficiencies in complying with the court order. View "State ex rel. Grooms v. Honorable Privette" on Justia Law