Wallace v. Frazier, 546 S.W.3d 624

Marjorie Frazier (pro se) appealed a judgment awarding her former landlord, Terry Wallace, $1,807 for rent, late fees, attorney's fees, and costs following a rent-and-possession action.
The appellate court previously struck Frazier’s initial brief for numerous violations of Missouri Rule 84.04 and granted 15 days to file an amended brief.
Frazier filed an amended brief that the court found still failed to comply with Rule 84.04: her Statement of Facts lacked record page references and was argumentative rather than a fair, concise recital of facts.
Her Points Relied On did not identify specific trial rulings with concise legal reasons or explain why those reasons support reversible error, forcing the court to speculate.
Her Argument section consisted of four one-paragraph, conclusory statements lacking legal analysis, record citations, preservation statements, and standard-of-review statements; the court deemed the deficiencies fatal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the appellate brief complies with Rule 84.04	Frazier argued multiple trial errors but submitted noncompliant brief sections and argumentative facts	Wallace relied on record judgment and procedural rules to oppose relief	Court held brief failed Rule 84.04 and preserved nothing for review; appeal dismissed
Whether trial court’s judgment was against weight/unsupported by evidence	Frazier claimed lease modified to tenancy-at-will and landlord breached duties (fire, habitability)	Wallace asserted judgment supported by evidence and presumptively correct	Not reached on merits due to briefing defects; appellant bears burden per Murphy v. Carron
Whether evidentiary rulings (fire report hearsay) and credibility findings were erroneous	Frazier contended the court mischaracterized the fire report as hearsay and improperly discredited witnesses	Wallace maintained trial court’s evidentiary and credibility rulings were within discretion	Not addressed on merits; court refused to speculate or act as appellant’s advocate
Whether tenant’s counterclaims for uninhabitable premises were supported	Frazier alleged latent defects and negligence causing an electrical fire, displacement, and hardships	Wallace disputed these factual/legal claims and relied on trial outcome	Not considered on merits because of inadequate briefing; appeal dismissed

Kim v. Kim, 431 S.W.3d 524 (Mo. App. 2014) (pro se appellants held to same briefing rules; deficient brief can lead to dismissal)
Summers v. Mo. Dep't of Corr., 459 S.W.3d 922 (Mo. App. 2015) (failure to comply with Rule 84.04 preserves nothing for review)
Nicol v. Nicol, 491 S.W.3d 266 (Mo. App. 2016) (statement of facts must give immediate, unbiased understanding; mere conclusions insufficient)
Treaster v. Betts, 297 S.W.3d 94 (Mo. App. 2009) (points relied on give notice of issues; abstract law alone insufficient)
Murphy v. Carron, 536 S.W.2d 30 (Mo. banc 1976) (bench-trial standard: appellant must show judgment erroneous, e.g., against weight of evidence)
Barnett v. Rogers, 400 S.W.3d 38 (Mo. App. 2013) (appellant bears burden to prove trial court error)