Justin D. O'Brien v. Department of Public Safety

Summary

The Supreme Court of Missouri affirmed the circuit court’s judgment upholding the Administrative Hearing Commission’s finding of cause and the Director’s order permanently revoking Justin O’Brien’s peace officer license. The Court held that the statute authorizing the AHC to determine whether an officer committed a criminal offense does not violate the separation‑of‑powers clause, and that the Director’s revocation was supported by competent and substantial evidence. The decision rests on de novo review of the constitutional challenge and a deferential competent‑and‑substantial‑evidence standard for the agency’s disciplinary action.