Justia Government & Administrative Law Opinion Summaries

Michael Holmes was convicted in 2006 of federal drug charges based on testimony from two St. Louis City police officers. After internal investigations revealed repeated misconduct by the officers, Holmes’ conviction was vacated in 2011 and the charges were dismissed, leading to his release after five years in prison. Holmes then sued the officers and the Board of Police Commissioners in federal court for civil rights violations and state torts. The federal district court dismissed the state tort claims against the board on sovereign immunity grounds and granted summary judgment to the board on the section 1983 claims, but the claims against the officers went to trial. A federal jury found the officers liable under section 1983 and awarded Holmes $2.5 million.Following this judgment, Holmes sought a declaration in the Circuit Court of the City of St. Louis that either the State of Missouri or the City of St. Louis was obligated to indemnify the officers and pay the judgment. The circuit court initially ruled the State was responsible for payment from the state legal expense fund. On appeal, the Supreme Court of Missouri held that the State was not obligated to pay under the applicable statute and remanded the case for a determination of the City’s liability.On remand, Holmes and the City filed cross-motions for summary judgment. The circuit court granted summary judgment to the City, finding Holmes had not established the City’s liability. Upon further appeal, the Supreme Court of Missouri reviewed the case de novo and held that Holmes failed to demonstrate that the City waived its sovereign immunity through express statutory consent or a recognized common law exception. As a result, the Supreme Court of Missouri affirmed the circuit court’s judgment in favor of the City, holding the City is not obligated to indemnify the officers for the federal judgment. View "Holmes vs. Zellers" on Justia Law

A resident of St. Louis brought a class action lawsuit against the city, seeking a refund of fees paid for solid waste services. The plaintiff alleged that these fees were collected under the mistaken belief that the city was providing separate recycling and yard waste collection, which the city either failed to provide or did not provide consistently. The city had implemented a monthly solid waste services fee in 2010, increased it in 2017, and included the fee in residents’ water bills. Although the city at times collected recyclables and yard waste separately, it often did not, and ultimately terminated the program in 2025. The plaintiff argued that the city unjustly retained fees for services it did not render, seeking damages for herself and other residents.The Circuit Court of the City of St. Louis denied the city’s motion to dismiss, finding that the plaintiff’s claim for “money had and received” could proceed. The city then sought a writ of prohibition from the Missouri Court of Appeals, which was denied. The city subsequently sought relief from the Supreme Court of Missouri.The Supreme Court of Missouri held that the city is protected by sovereign immunity and that section 432.070 of the Missouri Revised Statutes bars the claim. The court found that the plaintiff’s allegations did not plead facts that would establish an exception to sovereign immunity for her claim and that no statutory or recognized common law exception applied. The court also concluded that the proprietary function exception did not apply, as solid waste collection is a governmental function. The court made its preliminary writ of prohibition permanent, directing that the plaintiff’s claim be dismissed. View "State ex rel. City of St. Louis vs. Whyte" on Justia Law

A group of individuals who had filed claims with the Missouri Division of Workers’ Compensation for compensation from the tort victims’ compensation fund during the 2022 claims period alleged that the division failed to pay the full amount of compensation stipulated by statute. The division determined that each claimant was entitled to an award, but the payments were prorated at 40 percent of their respective full values due to the amount appropriated by the Missouri General Assembly being less than the total value of awards. The claimants contended the division should have based the proration on the total amount of money in the fund, not just on the appropriated amount, which would have resulted in a higher payout percentage.The claimants initiated lawsuits against the division, the Missouri Department of Labor and Industrial Relations, the Labor and Industrial Relations Commission, and associated officials, seeking declaratory and injunctive relief. After a bench trial, the Circuit Court of Cole County found in favor of the defendants, holding that the lawsuits were barred by sovereign immunity and that the claimants had failed to exhaust their administrative remedies. The circuit court also ruled, in the alternative, that the defendants’ interpretation of the relevant statute prevailed.Upon appeal, the Supreme Court of Missouri reviewed the case and affirmed the circuit court’s judgment. The Supreme Court held that the “sue and be sued” language in the enabling statutes for the division and commission did not constitute a waiver of sovereign immunity for this type of claim. The statutes governing the fund did not permit the claimants’ action, as the legislature explicitly barred claims against the state for unpaid or underpaid awards due to lack of appropriations. Additionally, the court found that claimants failed to exhaust the specific administrative review process provided by statute, which is the exclusive method for challenging such decisions. View "Jones vs. Missouri Labor and Industrial Relations Commission" on Justia Law

In September 2025, the Missouri General Assembly enacted HB 1, which redrew congressional districts despite no new census certification. Two Missouri voters, affected by the redistricting, signed and helped submit a referendum petition to challenge HB 1 before it took effect in December 2025. They argued that upon filing the petition with the secretary of state on December 9, 2025, HB 1 was automatically suspended under the Missouri Constitution until voters could decide on it. They also contended that any statutes allowing the secretary to delay suspension until official verification conflicted with constitutional provisions.The Circuit Court of Cole County held a bench trial on stipulated facts. It dismissed the voters’ petition on several grounds—lack of standing, lack of ripeness, the political question doctrine, and the existence of an adequate statutory remedy. On the merits, it also declared that filing the referendum petition did not automatically suspend HB 1. The voters appealed, and the Supreme Court of Missouri accepted transfer to review the important legal question presented.The Supreme Court of Missouri held that simply filing a referendum petition does not automatically suspend a legislative act under article III, sections 49, 52(a), or 52(b) of the Missouri Constitution. The Court reasoned that such suspension only occurs if the referendum petition is ultimately determined to be legal, sufficient, and timely, as required by constitutional and statutory provisions. The ongoing statutory process for verifying signatures and certification by the secretary of state must be completed to determine sufficiency. The Court also rejected the argument that the relevant statutes were unconstitutional as applied. The judgment of the circuit court was affirmed. View "Maggard vs. State" on Justia Law

After the Missouri General Assembly enacted Senate Bill No. 22 (SB 22) in 2025, which made several changes to statutes governing ballot summaries and judicial proceedings, a Missouri resident and taxpayer challenged its constitutionality. SB 22 as introduced focused solely on amending the process for judicial review of ballot summary statements. During the legislative process, SB 22 was amended to include provisions expanding the attorney general’s authority to appeal certain preliminary injunctions, a subject unrelated to ballot summaries, and the bill’s title was changed from “relating to ballot summaries” to “relating to judicial proceedings.” After passage by both legislative chambers and the Governor’s signature, the bill became law.The Circuit Court of Cole County reviewed the case after the plaintiff alleged SB 22 violated the Missouri Constitution’s original purpose, single subject, and clear title requirements, as well as equal protection guarantees. The circuit court found the bill did not violate the procedural constitutional provisions, but it did find that the amendment to section 526.010 (concerning the attorney general’s appellate rights) violated equal protection and was severable from the rest of the bill. The court allowed the remaining portions, primarily those addressing ballot summaries, to stand. The plaintiff appealed, challenging the findings on the procedural requirements, while the State cross-appealed on standing and equal protection.The Supreme Court of Missouri heard the case and held that the plaintiff had taxpayer standing because SB 22’s provisions resulted in a direct expenditure of public funds. Upon de novo review, the Supreme Court found that SB 22 violated the original purpose requirement of article III, section 21 of the Missouri Constitution because the added provision regarding the attorney general’s appellate rights was not germane to the bill’s original purpose. The Court further held that the offending provision could not be severed, and therefore invalidated SB 22 in its entirety, reversing the judgment of the circuit court. View "Nicholson v. State" on Justia Law

Phillip Weeks submitted a request under Missouri’s Sunshine Law to the St. Louis Metropolitan Police Department, seeking files containing traffic stop data from 2014 through 2018, specifically in spreadsheet (Excel) format and including officer identification numbers. The Department initially offered to provide traffic analysis reports with redacted officer numbers for a fee, which Weeks declined. During discovery in the resulting lawsuit, the City produced .CSV files containing the requested data. Weeks acknowledged these files matched his request in content but maintained he wanted the data in Excel spreadsheet format. Testimony at trial established that the Department did not maintain the data in Excel format, and there was conflicting evidence about whether the .CSV files could be accurately converted to Excel.The Circuit Court of the City of St. Louis found in favor of the City, concluding that the City did not possess an existing record in the specific format Weeks requested. The court determined that the City had not violated the Sunshine Law because it did not withhold any records it actually maintained in the requested format. Weeks appealed, arguing that the judgment was against the weight of the evidence, and also contended that the City’s admissions during litigation established it had responsive files at the time of his request.The Supreme Court of Missouri reviewed the case and affirmed the circuit court’s judgment. The Court held that Weeks failed to follow the required analytical framework for challenging a judgment as against the weight of the evidence. Specifically, he did not identify all favorable evidence supporting the judgment or address conflicting evidence in accordance with the trial court’s credibility determinations. The Court also found that the City’s admissions did not establish it possessed records in the requested format. The judgment in favor of the City was affirmed. View "Weeks vs. City of St. Louis" on Justia Law

Robust Missouri Dispensary 3, LLC, operates a dispensary in Florissant, an incorporated city in St. Louis County. After Missouri voters approved a constitutional amendment legalizing non-medical marijuana and allowing local governments to impose a 3 percent sales tax, both Florissant and St. Louis County enacted such a tax. Robust collected and remitted the tax to Florissant but not to St. Louis County. The Missouri Department of Revenue notified Robust that it must also remit the tax to St. Louis County. Robust sought declaratory and injunctive relief, arguing that the constitutional amendment only allows a village, town, or city in an incorporated area to impose the tax, not a county.The Circuit Court of St. Louis County granted summary judgment in favor of St. Louis and St. Charles Counties, finding that the definition of "local government" includes a county in an incorporated area. The court reasoned that excluding counties from the definition would frustrate the amendment's purpose of protecting public health. Robust appealed the decision.The Supreme Court of Missouri reviewed the case de novo and found that the plain language of the constitutional amendment distinguishes between incorporated and unincorporated areas. The court held that in an incorporated area, only a village, town, or city can impose the 3 percent sales tax, while in an unincorporated area, only a county can impose the tax. The court vacated the circuit court's judgment and remanded the case to enter judgment in favor of Robust, ruling that St. Louis County cannot impose the tax on sales within Florissant. View "Robust Missouri Dispensary 3, LLC v. St. Louis County" on Justia Law

Diana Penney, a pharmacy technician from 1980 to 2019, filed multiple work-related occupational disease claims due to repetitive activities at her job. She was diagnosed with low back issues, protruding disks in her neck and upper back, and carpal tunnel syndrome. Penney underwent surgeries and stopped working in August 2019 due to pain from these conditions. She sought permanent total disability (PTD) benefits from the Second Injury Fund (the Fund).An administrative law judge (ALJ) concluded that Penney was permanently and totally disabled due to the combined effect of her occupational diseases and awarded her PTD benefits from the Fund. The Fund appealed to the Labor and Industrial Relations Commission, arguing that the ALJ improperly considered Penney’s preexisting occupational diseases under the relevant statutory category. The Commission disagreed and affirmed the ALJ’s award.The Supreme Court of Missouri reviewed the case and held that preexisting occupational diseases do not qualify as preexisting disabilities under section 287.220.3(2)(a)a(ii)1, which requires the disability to be a “direct result of a compensable injury as defined in section 287.020.” The court noted that section 287.020 encompasses injuries by accident and explicitly excludes occupational diseases. The court emphasized that the legislature’s choice to reference only section 287.020 in the statute indicates an intent to limit qualifying preexisting disabilities to accidental injuries. Consequently, the court reversed the Commission’s decision, ruling that Penney’s preexisting occupational diseases could not be considered in determining her entitlement to PTD benefits from the Fund. View "Treasurer v. Penney" on Justia Law

Scott Frey was injured while riding his bike on the Katy Trail in March 2020. He alleged that his injury occurred when his bike tire became lodged between wooden motor-vehicle reinforcements on a bridge managed by the Department of Natural Resources. Frey had not paid any fee to enter the trail and was using it for recreational purposes. The department had installed the reinforcements shortly before the accident and had posted warning signs about the rough surface.Frey filed a personal injury lawsuit against the department, claiming the bridge's condition was dangerous due to the department's negligence. The department sought summary judgment, arguing it was protected from liability under the Recreational Use Act and the doctrine of sovereign immunity. The circuit court denied the department's motion, and the department's request for a writ of prohibition was also denied by the court of appeals.The Supreme Court of Missouri reviewed the case and determined that the Recreational Use Act provided the department with immunity from liability. The court found that the department met all the criteria for immunity under the Act: it owned the land, Frey entered without charge, and his entry was for recreational purposes. The court also concluded that the exceptions to the Act's protections did not apply, as there was no evidence of malicious or gross negligence by the department, nor was the condition of the bridge considered ultrahazardous. Consequently, the court made the preliminary writ of prohibition permanent, effectively barring Frey's claims against the department. View "State ex rel. Department of Natural Resources v. Crane" on Justia Law

Jessica Goodman, the Saline County Assessor, filed a lawsuit seeking a declaration regarding the correct classification of Saline County under Missouri law. Goodman argued that Saline County should be classified as a third-class county based on its assessed valuation over five years, rather than its current classification as a second-class county. The County moved to dismiss the petition, arguing that the statute in question, section 48.020.1, exempts Saline County from reclassification regardless of changes in assessed valuation.The Circuit Court of Saline County dismissed Goodman’s petition. Goodman appealed the decision to the Missouri Court of Appeals, Western District. The Court of Appeals transferred the case to the Supreme Court of Missouri, believing that the case involved the validity of a state statute, which would fall under the Supreme Court's exclusive jurisdiction.The Supreme Court of Missouri determined that it did not have exclusive appellate jurisdiction because Goodman did not properly raise a constitutional challenge to the statute in question. Goodman’s arguments against the County’s interpretation of the statute did not amount to a direct claim that the statute was unconstitutional. As a result, the Supreme Court of Missouri retransferred the case back to the Missouri Court of Appeals, Western District, for further proceedings. View "Goodman vs. Saline County Commission" on Justia Law