State of Missouri, et rel., Cass County, Missouri v. John R. Mollenkamp, Acting Director of The Missouri Department of Revenue, 481 S.W.3d 26

Director of Missouri Department of Revenue notified Cass County (June 16, 2014) that $966,692.35 was erroneously paid to Cass County due to KCPL/Aquila reporting, and proposed to recoup the overpayment by withholding specified local sales tax disbursements over three years beginning July 1, 2014.
Cass County filed a petition for a writ of prohibition (June 27, 2014) seeking to prevent Director from withholding funds, arguing Chapters 32 and 144 do not authorize such withholding and that §536.150 provided the proper vehicle for relief because no administrative remedy existed.
Director moved to quash, asserting authority under §32.087.6 to administer local sales taxes and that Cass County had an adequate administrative remedy (appeal to the Administrative Hearing Commission under §621.050 and related provisions).
Trial court issued a preliminary writ and later made it permanent, prohibiting Director from recovering funds from Cass County unless KCPL first filed a refund application under §144.190.
The Western District Court of Appeals reversed: it held prohibition was improper because Cass County had an adequate remedy by administrative appeal (AHC and judicial review), so the trial court abused its discretion in issuing the permanent writ; the case was remanded to quash the writ.

Issue	Plaintiff's Argument (Cass County)	Defendant's Argument (Director)	Held
Whether prohibition was an appropriate remedy to block Director from withholding local sales tax distributions	Director lacks statutory authority to withhold; no administrative review available, so §536.150 permits prohibition	Director has authority under §32.087 to administer/distribute and an administrative appeal exists to the AHC under §621.050	Prohibition inappropriate; adequate administrative remedy exists, so writ was an abuse of discretion and must be quashed
Whether Chapter 144 refund procedures (§144.190) must be triggered before Director may act to correct erroneous local distributions	Director cannot recoup from county until refund procedures (filed by taxpayer KCPL) are followed	Director’s decision to correct distributions is reviewable and within director’s authority; AHC review available even if §144.190 not invoked by taxpayer	Court treated the Director’s action as a decision subject to AHC review; Cass County must use administrative appeal rather than prohibition

State ex rel. Douglas Toyota III, Inc. v. Keeter, 804 S.W.2d 750 (Mo. banc 1991) (prohibition is extraordinary, not a substitute for appeal)
State ex rel. Riverside Joint Venture v. Mo. Gaming Comm’n, 969 S.W.2d 218 (Mo. banc 1998) (limits on use of prohibition; three categories where it lies)
State ex rel. Washington Univ. v. Richardson, 396 S.W.3d 387 (Mo. App. W.D. 2013) (appellate standard: review issuance of writ for abuse of discretion)
State ex rel. Baldwin v. Dandurand, 785 S.W.2d 547 (Mo. banc 1990) (denial of prohibition if adequate remedy by appeal exists)
Gettler v. Dir. of Revenue, 411 S.W.3d 339 (Mo. App. W.D. 2013) (AHC review of director’s decisions under §621.050)
City of Chesterfield v. Dir. of Revenue, 811 S.W.2d 375 (Mo. banc 1991) (appeal to AHC is proper route for disputes over director’s distribution decisions)
Alumax Foils, Inc. v. City of St. Louis, 939 S.W.2d 907 (Mo. banc 1997) (definition and scope of state "revenue laws" and appellate jurisdiction)