Bromwell v. Nixon
361 S.W.3d 393
| Mo. | 2012Background
- Inmates at Jefferson City Correctional Center filed a declaratory judgment petition and consolidated habeas petitions challenging MPLRA as applied to habeas writs.
- Cole County circuit court quashed service and dismissed habeas petitions without prejudice to refiling separately.
- Appellants seek appellate review claiming MPLRA violates US and Missouri constitutional provisions.
- Circuit court held there is no right to consolidate habeas petitions and dismissed claims for failure to state a claim.
- Appellants challenge the MPLRA’s indigent filing mechanics and access-to-courts implications under state open courts and due process principles.
- The Missouri Supreme Court has exclusive appellate jurisdiction to review constitutional challenges to MPLRA as applied under article V, section 3.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether consolidated habeas petitions were properly dismissed without prejudice | Bromwell argues consolidation is proper and warrants habeas relief | State contends consolidation was inappropriate and dismissal without prejudice was proper | Consolidated petitions were properly dismissed without prejudice |
| Whether the open courts and access-to-courts guarantees were violated | Inmates claim MPLRA filing fees restrict access to courts | MPLRA provisions do not bar filing and require only fees on an installment basis | No open courts or access-to-courts violation found |
| Whether the MPLRA as applied violates substantive due process | Appellants allege conscience-shocking treatment by filing fee requirements | Court held fee installment scheme not conscience-shocking | No due process violation found |
| Whether the allegedly insufficient legal resources violate constitutional rights | Inmates claim limited resources hinder litigation | No demonstrated hindrance to filing habeas petitions | Insufficient to state a claim; resources deemed adequate for meaningful access |
| Whether the declaratory judgment claims survive | Six constitutional challenges to MPLRA application | State officials immune or claims fail for lack of state action | Declaratory judgment claims dismissed for failure to state a claim |
Key Cases Cited
- Blackmon v. Mo. Bd. of Prob. and Parole, 97 S.W.3d 458 (Mo. banc 2003) (appeal from denial of habeas petition not allowed; separate petitioned paths exist)
- Hess v. Chase Manhattan Bank, USA, N.A., 220 S.W.3d 758 (Mo. banc 2007) (de novo review of dismissals for failure to state a claim)
- Nazeri v. Missouri Valley College, 860 S.W.2d 303 (Mo. banc 1993) (testing standard for failure to state a claim; pleading sufficiency)
- Lewis v. Casey, 518 U.S. 343 (1996) (meaningful access to courts; not actual injury without hindrance)
- Weigand v. Edwards, 296 S.W.3d 453 (Mo. banc 2009) (open courts doctrine; filing fee considerations not per se invalid)
- Wiglesworth v. Wyrick, 531 S.W.2d 713 (Mo. banc 1976) (writs of habeas corpus subject to reasonable regulation)
- State v. Nunley, 341 S.W.3d 611 (Mo. banc 2011) (abandoned constitutional arguments not asserted on appeal)
- Doe v. Phillips, 194 S.W.3d 833 (Mo. banc 2006) (due process interpretations linked to rights of access)