Medlin v. RLC, Inc.
423 S.W.3d 276
Mo. Ct. App.2014Background
- Medlin (subcontractor) sued RLC for breach of contract and enforcement of a mechanic’s lien arising from excavation work; Fifth Amended Petition included Counts I–V, with Count V (fraudulent transfer) severed for separate jury trial.
- Bench trial on Counts I–IV concluded; no evidence was ever presented on Count V and it remained severed.
- Trial court entered an Original Judgment on June 30, 2008, that awarded Medlin money, a mechanic’s lien on the subdivision (31 lots), and stated "No other Orders or Judgment are entered on counts, claims, counterclaims or cross-claims and therefore deemed denied and dismissed."
- Medlin timely filed a Rule 78.04 motion to amend (July 28, 2008); the court held a hearing (Sept. 11, 2008) but did not rule within 90 days. The court later entered a First Amended Judgment (June 29, 2009) and a Second Amended Judgment (Dec. 28, 2010) awarding increased interest.
- Intervenors moved to vacate the amended judgments, arguing the court lacked jurisdiction to enter them because the after-trial motion was overruled by operation of law; the trial court reinstated the Original Judgment and vacated the amended judgments.
- On appeal, the Missouri Court of Appeals affirmed: because the authorized after-trial motion was not ruled on within 90 days it was overruled by operation of law, the Original Judgment became final, and later "amendments" were void.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether amended judgments entered after the court failed to rule on a timely after-trial motion within 90 days were void. | Medlin argued the court could amend the Original Judgment and enter the later amended judgments. | Intervenors argued the after-trial motion was overruled by operation of law after 90 days, so the court lacked jurisdiction to enter amendments. | Held: The motion was deemed overruled by operation of law; amended judgments entered after the 90-day period were void and properly vacated. |
| Whether the Original Judgment was final when it appeared to dismiss all other counts despite Count V being severed and untried. | Medlin argued the Original Judgment was not a final Rule 74.01 judgment because Count V remained severed and unadjudicated. | Intervenors argued the Original Judgment on its face disposed of all counts and thus was final. | Held: The plain language of the Original Judgment dismissed all other counts (including Count V); once the after-trial motion was overruled, the Original Judgment was final. |
| Whether the trial court could later amend the Original Judgment under Rule 74.06 without showing relief grounds. | Medlin argued equitable ability to correct errors and proceed. | Intervenors argued Rule 74.06 relief was required and was not sought or shown. | Held: The court lacked authority to amend the final judgment absent proper Rule 74.06 relief; it did not make such findings, so amendments were void. |
| Standard of review for vacating a void judgment. | — | — | Held: Whether a judgment is void is a question of law reviewed de novo; court applied de novo review. |
Key Cases Cited
- Sieg v. Int’l Envtl. Mgmt., Inc., 375 S.W.3d 145 (Mo. Ct. App. 2012) (standard of review for void-judgment issue)
- Dunkle v. Dunkle, 158 S.W.3d 823 (Mo. Ct. App. 2005) (after-trial motions extend court's control up to 90 days)
- Carson v. Brands, 7 S.W.3d 576 (Mo. Ct. App. 1999) (after-trial motion overruled by operation of law if not ruled on within 90 days; original judgment becomes final)
- In re Marriage of Noles, 343 S.W.3d 2 (Mo. Ct. App. 2011) (amended judgment entered after 90-day period is nullity)
- Hollaran v. St. Louis Investigations Agency Inc., 308 S.W.3d 299 (Mo. Ct. App. 2010) (void judgments may be challenged at any time)
- Lombardo v. Lombardo, 120 S.W.3d 232 (Mo. Ct. App. 2003) (plain language of judgment controls interpretation)
- Gaunt v. State Farm Mut. Auto. Ins. Co., 24 S.W.3d 130 (Mo. Ct. App. 2000) (when judgment language is plain there is no room for construction)
- Colborne v. Colborne, 337 S.W.3d 158 (Mo. Ct. App. 2011) (do not look beyond the four corners when language is unambiguous)