Glendale Shooting Club, Inc., Respondent v. William K. Landolt and Jeri F. Landolt, Appellants., SC101187

Glendale acquired property next to the Racines in 1976 and was permanently enjoined in 1987 from certain firing-range operations after a nuisance action. 1
The injunction limited shooting competitions, member shooting hours, and use of firearms above .22 caliber. 2
The court of appeals affirmed the 1987 injunction in Racine v. Glendale Shooting Club, Inc. 3
After Missouri enacted section 537.294 granting firearm-range immunity, Glendale repeatedly sought to dissolve the injunction and this Court remanded once in Glendale I for proper weighing of equities. 4
On remand, the circuit court again set aside the injunction after a bench trial, finding changed conditions at Glendale's property made continued enforcement inequitable. 5
The Landolts appealed, challenging the reliance on section 537.294, the sufficiency of the evidence, and the denial of a jury trial. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a change in law alone justified dissolving the injunction 7	Landolts argued section 537.294 alone could not make enforcement inequitable.	Glendale argued the statute supported relief from the injunction.	Change in law alone was insufficient; the statute was not the sole basis for affirmance. 8
Whether changed property conditions made continued enforcement inequitable 9	Landolts said evidence did not show the nuisance was abated.	Glendale said sound barriers and other changes reduced noise enough to make the injunction inequitable.	Yes; the circuit court properly weighed the equities and did not abuse its discretion. 10
Whether the Landolts were entitled to a jury trial 11	Landolts claimed a jury trial was required.	Glendale argued Rule 74.06(b) relief is equitable, not legal.	No jury-trial right existed in this equitable proceeding. 12

Racine v. Glendale Shooting Club, Inc., 755 S.W.2d 369 (Mo. App. 1988) (affirmed the original nuisance injunction against Glendale 13)
Landolt v. Glendale Shooting Club, Inc., 18 S.W.3d 101 (Mo. App. 2000) (earlier appeal reversing dismissal of Glendale's motion to dissolve the injunction 14)
Glendale Shooting Club, Inc. v. Landolt, 661 S.W.3d 778 (Mo. banc 2023) (Rule 74.06(b)(5) requires weighing equities; change in law alone is insufficient 15)
City of Normandy v. Kehoe, 709 S.W.3d 327 (Mo. banc 2025) (abuse-of-discretion review and equity balancing for Rule 74.06(b) relief 16)
City of Normandy v. Parson, 643 S.W.3d 311 (Mo. banc 2022) (Rule 74.06(b) motions are equitable and require weighing changed circumstances 17)
Bate v. Greenwich Ins. Co., 464 S.W.3d 515 (Mo. banc 2015) (cited for Rule 74.06(b) review standard 18)
Archdekin v. Archdekin, 562 S.W.3d 298 (Mo. banc 2018) (appellate courts may affirm on any correct theory 19)
Business Men's Assurance Co. of America v. Graham, 984 S.W.2d 501 (Mo. banc 1999) (appellate courts affirm judgments under any correct theory 20)
State ex rel. Diehl v. O'Malley, 95 S.W.3d 82 (Mo. banc 2003) (there is no jury-trial right in actions at equity 21)