City of St. Louis v. State
2012 Mo. LEXIS 276
| Mo. | 2012Background
- Missouri enacted section 320.097 in 2010, exempting certain veteran firefighters from residency requirements if their district’s public schools are unaccredited or provisionally accredited.
- Seven-year firefighters may reside outside their department’s area but within a one-hour response-time if eligible under section 320.097.
- St. Louis, a constitutional charter city, requires all permanent city employees to reside in the city within 120 days of employment and thereafter.
- The City and its officials sued to block application of section 320.097, arguing it violates the state’s local-law prohibition, home-rule protections, and equal protection.
- The trial court held section 320.097 is not a special law but erred in concluding it violated the home-rule constitution; it also found equal protection issues, applying a higher standard.
- The Missouri Supreme Court affirmed that section 320.097 is not a special law, held it does not infringe on home-rule powers, and rejected equal-protection challenges as rationally related to legitimate state interests.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is section 320.097 a special law under Art. III, §40? | City: statute targets a local matter and is facially special. | State: open-ended classification; not facially special. | Not a special law |
| Does §320.097 conflict with Art. VI, §22 home-rule protections? | City: residency qualifications fall under home-rule powers; statute impermissibly interferes. | State: residency rules are not powers, duties, or compensation; statute does not fix city authority. | No violation; not interference with home rule |
| Does §320.097 violate equal protection? | City: rational basis not satisfied; statute lacks legitimate purpose. | State: rational-basis review applies; classification plausibly furthers education improvement and retention of firefighters. | Not violative; rational basis supported |
Key Cases Cited
- Jefferson County Fire Prot. Dists. Ass’n v. Blunt, 205 S.W.3d 866 (Mo. banc 2006) (open-ended vs. narrow classifications for special-law analysis)
- St. Louis Fire Fighters Ass’n v. Stemmler, 479 S.W.2d 456 (Mo. banc 1972) (state may regulate employment qualifications; home-rule limits protect powers, duties, compensation)
- City of Springfield v. Goff, 918 S.W.2d 786 (Mo. banc 1996) (legislature may affect city employees so long as it does not fix powers, duties, or compensation)
- City of St. Louis v. Grimes, 680 S.W.2d 82 (Mo. banc 1982) (legislature may enact laws affecting city employees unless restricted by constitution)
- O’Reilly v. City of Hazelwood, 850 S.W.2d 96 (Mo. banc 1993) (open-ended vs. closed-ended classification analysis in special-law context)
- Tillis v. City of Branson, 945 S.W.2d 447 (Mo. banc 1997) (open-ended classifications generally not facially special law)