Missouri Department of Corrections, et al. Missouri Cases

Aaron Barker appealed the grant of judgment on the pleadings in his declaratory judgment action against the Missouri Department of Corrections and the State of Missouri. Barker sought jail-time credit for a period he was on parole for one consecutive sentence while awaiting sentencing on another. The appellate court affirmed the trial court's decision, holding that Section 558.031.1(1) prohibits applying jail-time credit for the same period to two consecutive sentences, even if one credit was for time on parole.

Thomas Iseman, incarcerated for felony harassment, sought a declaratory judgment that he is not required to register as a sex offender under Missouri's Sex Offender Registration Act (SORA). The circuit court dismissed his petition, finding the claim unripe and that an adequate remedy existed under § 589.401. The Western District reversed, holding that Iseman's pre-enforcement challenge was ripe and that § 589.401 did not provide an adequate remedy for his specific claim, remanding the case for a determination of the underlying facts of his convictions.

Timis Cobbins appealed the circuit court's summary judgment in favor of the Missouri Department of Corrections (DOC), which sought to require him to serve eighty percent of his prison sentence before parole eligibility. Cobbins argued that his 2011 second-degree robbery conviction was not among the predicate offenses listed in the current version of section 558.019, RSMo, which mandates minimum prison terms. The appellate court reversed the summary judgment, holding that the elements of Cobbins's 2011 offense were not "contained in" the enumerated predicate offenses in the 2019 version of section 558.019.2, RSMo, due to legislative changes in the definition of second-degree robbery.

Lawrence Belk appealed the circuit court's judgment granting the Department of Corrections' motion for judgment on the pleadings. Belk argued the Department erred in recalculating his parole eligibility date, violating ex post facto laws, and that he had no liberty interest in his earlier parole date. The appellate court affirmed the circuit court's judgment, as modified, holding that the Department correctly applied statutory interpretations to recalculate Belk's parole eligibility and that no ex post facto violation occurred. The court also found Belk had no protected liberty interest in a miscalculated parole date and modified the judgment to reflect the Department's most recent recalculation of Belk's minimum parole eligibility to December 2073.

Charles Harris, a former employee, sued the Missouri Department of Corrections for discrimination and retaliation under the MHRA. After a default judgment was entered against the Department, the trial court awarded Harris compensatory and punitive damages, and later attorneys' fees. The Department appealed the attorneys' fee award, arguing the trial court lacked authority due to a venue change motion, erred in entering default, and abused discretion in denying their motion to set aside default. The appellate court affirmed the trial court's award of attorneys' fees, finding Harris remained the prevailing party, and remanded for the trial court to determine and award Harris reasonable appellate attorneys' fees.