424 S.W.3d 450
Mo.2014Background
- Section 57.278 creates a deputy sheriff salary supplementation fund and levies a $10 service of process fee remitted to the fund.
- MoSMART grants may supplement salaries/benefits of county deputy sheriffs, with eligibility tied to the Sheriff of the county.
- St. Louis County and county officials applied for a grant on behalf of the superintendent of police, but MoSMART denied it because the application lacked the Sheriff as signer.
- Plaintiffs filed a four-count petition for declaratory judgment challenging Section 57.278 and MoSMART processes, including standing to sue and accountability of MoSMART's grant decisions.
- The circuit court dismissed for lack of standing and sovereign immunity; the court of appeals reversed only as to Count IV for standing issues related to the superintendent; otherwise affirmed and remanded.
- The Supreme Court held Counts I-III lacked standing, but Count IV could proceed to the extent the superintendent could have standing to challenge MoSMART’s denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Do Counts I–II have standing to challenge §57.278 and MoSMART’s actions? | Plaintiffs claim legally protectable interests in grants and in avoiding the $10 fee. | MoSMART and state argue no legally protectable interest in discretionary grants or filing fees. | Counts I–II lack standing. |
| Does Count III have standing to challenge grant-criteria promulgation? | Plaintiffs seek invalidation of non-promulgated criteria as a remedy for denial of grant. | No direct injury remedied by such declaration; no standing to challenge criteria alone. | Count III lacks standing. |
| Does Count IV confer standing to challenge MoSMART’s grant denial on behalf of the superintendent? | Superintendent has a legally protectable interest to obtain review of eligibility and grant-denial. | Other plaintiffs lack standing; superintendent’s standing is uncertain if he isn’t an eligible Sheriff. | Superintendent has standing; circuit court erred in dismissing Count IV regarding him. |
Key Cases Cited
- Roberts v. BJC Health System, 391 S.W.3d 433 (Mo. banc 2013) (standing requires a legally protectable interest and personal stake)
- Battlefield Fire Protection District v. City of Springfield, 941 S.W.2d 491 (Mo. banc 1997) (standing requires a direct or legally protected interest)
- Mo. State Medical Ass'n v. State, 256 S.W.3d 85 (Mo. banc 2008) (de novo review for standing questions on appeal)
- Foster v. State, 352 S.W.3d 357 (Mo. banc 2011) (assume pleadings true for standing analysis)