574 S.W.3d 239
Mo.2019Background
- AJKJ, Inc. sued to reform a deed it had conveyed to New Sites, alleging mutual mistake in omitting the phrase "including developer rights."
- Bench trial was held; court entered judgment on July 19, 2018, reforming the deed to include developer rights.
- On August 14, 2018 (within 30 days), several Birch Creek residents ("Residents") filed a motion to intervene and a Rule 74.06(b) motion to set aside the judgment.
- The circuit court did not rule on those motions until September 13, 2018 (more than 30 days after judgment) and then sustained the motions, vacating the reformation judgment.
- AJKJ sought a writ of prohibition; the Missouri Supreme Court held the reformation judgment became final 30 days after entry, the court lacked jurisdiction after that point, and the post-final rulings were void.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the circuit court had jurisdiction to rule on Residents’ motion to intervene after 30 days from judgment | AJKJ: court lost jurisdiction 30 days after judgment; non-party motions cannot extend jurisdiction | Residents: their motion to intervene was timely filed and should allow further proceedings | Held: Motion to intervene filed by non-parties did not extend jurisdiction; ruling on it after 30 days was void |
| Whether a non-party’s Rule 74.06(b) motion to set aside extends the court’s jurisdiction beyond 30 days | AJKJ: Rule 74.06(b) relief is limited to parties and cannot extend jurisdiction for non-parties | Residents: Rule 74.06(b) motions can function as independent actions and permit relief despite the 30-day limit | Held: Rule 74.06(b) relief is limited to parties; Residents were never parties, so the motion did not extend jurisdiction |
| Whether the Rule 81.05 timing rules allow retention of jurisdiction for 90 days absent authorized after-trial motions | AJKJ: Rule 81.05 allows 90-day retention only if an authorized after-trial motion is filed by a party within 30 days | Residents: their filings should be treated as authorized to toll finality | Held: Only authorized after-trial motions by parties toll finality per Rule 81.05; non-party motions do not |
| Whether precedent treating certain post-judgment motions as independent (e.g., default-judgment relief) controls here | AJKJ: cases distinguishing Rule 74.05 (default-judgment) from Rule 74.06 (merits) mean those precedents do not apply | Residents: analogies to cases allowing later intervention or relief should permit their motions | Held: Cases involving Rule 74.05 are distinguishable; Rule 74.06 does not create an independent action that avoids Rule 81.05 timing |
Key Cases Cited
- Spicer v. Donald N. Spicer Revocable Living Trust, 336 S.W.3d 466 (Mo. banc 2011) (authorized after-trial motions are limited to parties; judgment finality rules)
- State ex rel. Hawley v. Pilot Travel Ctrs., Inc., 558 S.W.3d 22 (Mo. banc 2018) (Rule 81.05 tolling requires timely authorized after-trial motion by a party)
- State ex rel. Wolfner v. Dalton, 955 S.W.2d 928 (Mo. banc 1997) (Rule 74.06(b) relief limited to parties; court lacked jurisdiction to act after judgment became final)
- Taylor v. United Parcel Serv., Inc., 854 S.W.2d 390 (Mo. banc 1993) (catalogue of commonly recognized authorized after-trial motions)
- Massman Const. Co. v. Mo. Highway & Transp. Comm’n, 914 S.W.2d 801 (Mo. banc 1996) (once 30-day Rule 75.01 period expires, relief is limited to grounds raised in timely authorized motions)