Justia Injury 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

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 made permanent a preliminary writ it issued granting Monsanto Company's petition for a writ of prohibition or mandamus requiring the St. Louis circuit court to transfer venue of five of the six plaintiffs' claims, holding that Missouri law compelled this result.Plaintiffs brought this action claiming that they were injured as a result of exposure to a herbicide manufactured by Monsanto Company and seeking monetary damages. Monsanto filed a motion to transfer venue as to five of the six plaintiffs in this case to St. Louis County but failed to file a motion to transfer in the six plaintiff's case The circuit court subsequently consolidated Plaintiffs' individual claims. Monsanto filed a motion to reconsider, arguing that venue was inappropriate in St. Louis Valley. The circuit court overruled the motion, after which Monsanto sought relief by way of mandamus or prohibition. The Supreme Court granted relief, holding that Mo. Rev. Stat. 508.010.5(1) mandated that venue shall be where Monsanto's registered agent was located as of filing - St. Louis County. View "State ex rel. Monsanto Co. v. Honorable Mullen" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing the underlying wrongful death lawsuit, holding that the allegations of the petition established that Crystal May was entitled to official immunity, as a matter of law, and therefore, the petition failed to state a claim upon which relief could be granted.Plaintiff brought a wrongful death suit against May, alleging that May, a children's division caseworker, owed M.S., a toddler who died from a fentanyl overdose, a ministerial duty to make a SAFE CARE provider referral and that the failure to make such a referral under after M.S. died resulted in M.S.'s death. The circuit court dismissed the petition, finding that May was entitled to official immunity and that the complaint failed to allege sufficient facts establishing that May caused M.S.'s death. The Supreme Court affirmed, holding that the allegations of Plaintiff's petition established that May was entitled to official immunity as a matter of law. The Supreme Court affirmed, holding that the allegations in the petition established that May was entitled to official immunity as a matter of law. View "Forester v. May" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Plaintiff's challenge to the constitutional validity of Mo. Rev. Stat. 303.390, which prohibited Plaintiff from collecting noneconomic damages in her personal injury lawsuit filed against Defendant, with whom she had been in a motor vehicle accident, holding that Plaintiff was not entitled to relief.At the time of the underlying accident, Plaintiff was an uninsured motorist prohibited from recovering noneconomic damages under section 303.390. The circuit court awarded Plaintiff economic damages for her medical bills but denied her renewed motion to strike Defendant's affirmative defense regarding section 303.390. The Supreme Court affirmed, holding that Plaintiff failed properly to preserve her constitutional argument for appellate review. View "Bridegan v. Turntine" on Justia Law

The Supreme Court reversed the judgment of the circuit court dismissing Petitioner's petition seeking relief from fraudulent transfers Respondent made to hinder collection of her judgments against him, holding that Petitioner adequately alleged facts that, if true, entitled her to relief under the Uniform Fraudulent Transfers Act (UFTA), Mo. Rev. Stat. 428.005 to 428.059.On appeal, Petitioner argued that she alleged facts that, if taken as true, demonstrated that she was Respondent's creditor and that he made two transfers with the actual intent to hinder, delay, or defraud her and, regarding one of the transfers, without receiving an equivalent value in exchange and either was insolvent or became insolvent as a result of the transfer. The Supreme Court agreed and remanded the case, holding that Petitioner adequately pleaded a claim for relief under both Mo. Rev. Stat. 428.024.1(1) and Mo. Rev. Stat. 928.029.1. View "Konopasek v. Konopasek" on Justia Law

The Supreme Court quashed a preliminary writ of prohibition granted to the Kristine and Dennis Hill preventing the circuit court from compelling production of certain settlement documents relating to a motor vehicle accident involving Kristine in this negligence lawsuit brought against Mercy Rehabilitation Hospital, holding that the documents were not protected by the work product doctrine.Kristine was a patient at Mercy recovering from back surgery when her hospital bed allegedly malfunctioned in a manner causing her to sustain back and spine injuries. Six months later, Kristine was involved in an accident that allegedly aggravated those injuries. After Kristine settled her claim with the insurance carrier of the at-fault driver the Hills sued Mercy, alleging negligence. Mercy sought production of the settlement documents to prove reduction, but the Hills identified as protected work product several of those documents. The circuit court sustained Mercy's ensuing motion to compel production of the documents, and the Halls petitioned for a writ of prohibition. The court of appeals issued a preliminary writ. The Supreme Court quashed the writ, holding that the circuit court properly concluded the settlement documents and related communications Mercy sought were not protected by the work product doctrine. View "Hill v. Honorable Wallach" on Justia Law

The Supreme Court affirmed the judgment of the circuit court sustaining the motion to dismiss filed by the City of St. Charles due to Plaintiff's failure to provide notice of suit, as required by section 12.3 of the City of St. Charles Charter, holding that Plaintiff's claims on appeal failed.Plaintiff filed a lawsuit against the City of St. Charles and St. Charles County seeking damages incurred as a result of falling off his bike while riding across an open-grated metal bridge, alleging negligence and premises liability. The City filed a motion to dismiss, arguing that the premises liability claim was barred because Plaintiff failed to give proper notice, as required by section 12.3 of the Charter. The circuit court sustained the motion and dismissed the premises liability claim. Plaintiff appealed, arguing that the Charter's notice requirement conflicted with various statutes and must be stricken. The Supreme Court affirmed, holding that there was no irreconcilable conflict between section 12.3 of the Charter and the statutes cited by Plaintiff. View "Zang v. City of St. Charles" on Justia Law

The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission affirming and adopting the ALJ's final award denying Appellant's claim for benefits from the Second Injury Fund, holding that the Commission did not abuse its discretion in affirming the ALJ's denial of Appellant's post-hearing motions to reopen the record and submit additional evidence.Before the ALJ issued her final award, the Supreme Court decided Cosby v. Treasurer of Missouri, 579 S.W.3d 202 (Mo. banc 2019), which reached a different interpretation of Mo. Rev. Stat. 287.220.3 than that reached by the court of appeals in Gattenby v. Treasurer of Missouri, 516 S.W.3d 859 (Mo. App. 2017). Before the ALJ's final award, Appellant filed a motion to reopen the record for a supplemental hearing based on Cosby. The ALJ overruled the motion and issued her award. The Commission affirmed. The Supreme Court affirmed, holding that the Commission did not abuse its discretion in overruling Appellant's motions to reopen the record and submit additional evidence. View "Weibrecht v. Treasurer of Mo. as Custodian of Second Injury Fund" on Justia Law