Lanham v. Division of Employment Security, 340 S.W.3d 324

Lanham was a van driver for Heartland Regional Medical Center from 1998 to 2009, and was discharged for failing to provide a drug test and admitting the test would be positive.
Division of Employment Security disqualified Lanham for misconduct; the Appeals Tribunal vacated to find she voluntarily quit; the Commission later found misconduct; Lanham appealed.
On September 28, 2009, Mueller received an anonymous report of possible methamphetamine use by Lanham, prompting a drug-test request under the employer's policy.
Lanham initially agreed to test; taken to the health department; a small urine sample was insufficient, and three hours were spent waiting for an adequate sample.
Employer testimony suggested Lanham admitted a drug problem; Lanham denied such admission; the Commission found Lanham left and refused to provide a sufficient sample, supporting a misconduct finding.
The court dismissed Lanham's appeal due to severe briefing deficiencies under Rule 84.04, and noted no reviewable issues were raised.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the appeal should be dismissed for briefing deficiencies	Lanham argues merits should be reviewed despite pro se status.	Defendant contends briefing failures warrant dismissal under Rule 84.04.	Dismissed for briefing deficiencies

Yates v. Briggs & Stratton, 302 S.W.3d 776 (Mo. 2010) (briefing deficiencies are reviewed under Rule 84.04)
Coyne v. Coyne, 17 S.W.3d 904 (Mo. App. E.D. 2000) (mandatory briefing requirements for pro se litigants)
Bamber v. Dale Hunt Trucking, 107 S.W.3d 489 (Mo. App. S.D. 2003) (dismissal when briefing deficiencies impede disposition on merits)
Krause v. Assurant, Inc., 158 S.W.3d 329 (Mo. App. S.D. 2005) (prefer resolving merits but may dismiss for briefing defects)
Bishop v. Metro Restoration Services, Inc., 209 S.W.3d 43 (Mo. App. S.D. 2006) (exercises discretion to resolve briefing issues; caution against speculation)