Am. Eagle Waste Indus. v. St. Louis County

In 2008, St. Louis County (County) assumed control of solid waste collection in County's unincorporated areas. Prior to that, waste collection services had been provided by private entities, including respondent Haulers. Following a 2007 amendment to Mo. Rev. Stat. to 260.247, which extended hauler-protective business regulations to counties that wish to provide trash collection, Haulers sued County for a declaratory judgment that County must comply with section 260.247. Haulers also claimed they suffered money damages as a result of County's failure to comply with the statute. The circuit court found County liable to Haulers on the theory of implied in law contract and awarded Haulers $1.2 million in damages. The Supreme Court (1) reversed the circuit court's calculation of damages, holding that the circuit court was incorrect to exclude discovery or evidence of Haulers' expenses or net profit; and (2) affirmed the judgment in all other respects. Remanded.