Flower Valley, LLC, 12667 New Valley, LLC, John C. Crocker, NOLOB, LLC, Keeven Development, LLC, Dunwood Development Co., French Quarter, LLC, Glidepath, LLC v. Jake Zimmerman, Assessor, St. Louis County, Missouri, 575 S.W.3d 497

St. Louis County Assessor Jake Zimmerman assigned 2011–2012 assessed values to multiple property owners (Respondents), who appealed to the county BOE and then to the State Tax Commission (STC).
Respondents presented appraisals and testimony; Zimmerman presented no contrary evidence and the STC reduced assessed values substantially, triggering statutory/ordinance-based fee-reimbursement rights.
Respondents contracted with Property Assessment Review (PAR), which paid attorneys’ fees and appraisal costs; Respondents agreed to pay PAR a contingency fee on tax savings.
Respondents filed a consolidated application for reimbursement under section 138.434 and St. Louis County Ordinance §503.300; the STC initially ordered reimbursement, then, after remand, denied reimbursement on the ground PAR — not the taxpayers — paid fees.
The trial court, on judicial review, reversed the STC’s remand order, reinstated the STC’s original reimbursement award, and also found Respondents entitled to additional attorneys’ fees for the litigation over reimbursement but left the amount to be determined later; the court certified the partial judgment under Mo. Sup. Ct. R. 74.01(b).
The Court of Appeals dismissed Zimmerman’s appeal for lack of jurisdiction because the trial court’s Rule 74.01(b) certification was improper: it had not finally disposed of the single legal claim (the unresolved award-amount for post-application attorneys’ fees remained open).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court's Rule 74.01(b) certification produced a final, appealable judgment	Respondents argued the court disposed of the claim by awarding reimbursement and declaring entitlement to additional fees, so certification was proper	Zimmerman argued the judgment was not final because the court left the amount of additional attorneys’ fees undetermined	The court held the certification was improper; judgment was not final because it left the amount of post-application attorneys’ fees unresolved, so appellate jurisdiction is lacking
Whether the STC erred in denying reimbursement on remand (merits)	Respondents contended the statute/ordinance do not require direct payment by the taxpayer to recover fees, so reimbursement should be awarded	Zimmerman contended reimbursement was improper because PAR, not the taxpayers, paid fees	The court did not reach the merits due to lack of appellate jurisdiction

Gibson v. Brewer, 952 S.W.2d 239 (Mo. banc 1997) (trial-court Rule 74.01(b) certification does not end finality analysis)
First Nat'l Bank of Dieterich v. Pointe Royale Property Owners' Ass'n, 515 S.W.3d 219 (Mo. banc 2017) (separate transactions/occurrences, not legal theories, permit separate final judgments)
Shea v. Gaither, 389 S.W.3d 725 (Mo. App. E.D. 2013) (a judgment leaving remedies for later determination is not final under Rule 74.01(b))
Columbia Mut. Ins. Co. v. Epstein, 200 S.W.3d 547 (Mo. App. E.D. 2006) (one claim defined as one legal right; partial resolution must dispose of a complete claim)
Rheem Mfg. Co. v. Progressive Wholesale Supply Co., 28 S.W.3d 333 (Mo. App. E.D. 2000) (authority supporting that unresolved attorneys’ fees prevent finality)
Hackathorn v. Four Seasons Lakesites, Inc., 959 S.W.2d 954 (Mo. App. S.D. 1998) (same)