Missouri State Highway Patrol, et al Missouri Cases

Appellants K.A.C. and Michael Crites, Jr. sued the Missouri State Highway Patrol for wrongful death after a pursued driver collided with and killed Connor Crites. The trial court granted summary judgment for MSHP, finding Appellants failed to establish proximate cause. The appellate court affirmed, holding that Appellants did not produce sufficient facts to prove MSHP's actions were the proximate cause of the collision, consistent with Supreme Court precedent that proximate cause cannot be based on speculation in police pursuit cases.

J.M.L. filed a petition to be removed from the Missouri sex offender registry, which the circuit court granted. The Missouri State Highway Patrol appealed, arguing the circuit court erred by not determining if J.M.L. was required to register under federal SORNA. The appellate court reversed the circuit court's judgment and remanded the case for further proceedings, finding that an incomplete record on appeal prevented proper review of the claim.

Gary Austin appealed the denial of his petition to be removed from the Missouri Sex Offender Registry. Austin argued that his subsequent felony convictions and failure to complete probation occurred before his duty to register under the federal Sex Offender Registration and Notification Act (SORNA), and thus should not preclude his removal. The appellate court affirmed the trial court's judgment, clarifying that Austin's registration duty arose under Missouri's Sex Offender Registration Act (SORA) and that the statutory conditions for removal were not met due to events occurring after his SORA registration obligation began.

Kimberly Harper and Sharon Kay Harper sought an injunction under the Missouri Sunshine Law against the Missouri State Highway Patrol (MSHP) to disclose records related to the shooting of Cpl. Bob Harper. The circuit court denied disclosure, finding the records protected under the federal Freedom of Information Act (FOIA). The appellate court reversed, holding that FOIA does not preempt the Sunshine Law for state agency records and that the records retained by MSHP are not "agency records" for FOIA purposes, thus making them subject to disclosure under state law.