Case summaries for Sept. 4-10, 2026

Appellate | Attorneys | Criminal | Elections | Family | Workers' compensation

Appellate

Special orders after judgment explained
Appeals were possible from special orders after judgment. Special orders after judgment related to the accomplishing or preventing enforcement of a judgment. Special orders after judgment did not include a ruling on the appellant’s declaratory judgment action. That action sought clarification of an underlying circuit court action’s status but did not seek relief related to enforcement of the judgment in that underlying action. The Missouri Court of Appeals dismissed the appeal.
(Overview summary)
City of Richmond Heights, Missouri, Respondent, v. Clinton L. Watson, Appellant.
Missouri Court of Appeals, Eastern District - ED114255

Appellant’s briefing deficiencies barred review
The appellants had the burden of showing that the circuit court committed reversible error by filing an appellant’s brief. Appellants’ briefs were subject to rules that protected the courts’ impartiality by requiring appellants to set forth their challenges in a specified format. That format included a statement of facts, with references to the record and without argument, relevant to the judgment. It also required points relied on that, in a specified template, alleged circuit court error and a theory for reversal. Each theory required support with an argument in a respective prescribed analysis. When the appellant charged reversible error in any ruling, the appellants had to state how they preserved that error for review and the standard of review for the ruling. The appellant’s brief failed to conform to those requirements, requiring an appellate to construct an argument for the appellant, which courts would not do. The Missouri Court of Appeals granted the respondents’ motion to dismiss the appeal.
(Overview summary)
Steven M. Young, et al., Respondents v. William H. Young, Appellant.
Missouri Court of Appeals, Eastern District - ED113691

Attorneys

Use of AI’s fictitious citations merited sanctions
Every filing in every tribunal constituted a certification that the allegations and arguments had a basis in law and fact, which required some pre-filing inquiry. Counsel violated both the inquiry and certification requirements when counsel cited fabricated authorities for fictitious legal propositions hallucinated by generative artificial intelligence results. “Improper or careless use of generative AI” might also have violated “multiple rules of professional conduct.” Failure to check AI results was objectively unreasonable and supported a monetary sanction against counsel. The Missouri Court of Appeals denied the petition and ordered petitioner’s counsel to pay an amount for the adverse parties’ reasonable attorney fees.
(Overview summary)
State of Missouri ex rel. Steven Schnell, Relator, v. Honorable Rebecca Richardson, Respondent.
Missouri Court of Appeals, Eastern District - ED114731

Criminal

Revocation of parole prohibited
Writs of prohibition issued “to avert the usurpation of power when a lower court lacks authority or jurisdiction[.]” Sentencing defendants to the custody of the Department of Corrections ended the authority of the circuit court and started the authority of the Department, including as to parole. The respondent circuit judge nevertheless issued a summons and a warrant on the State’s motion to revoke the parole of the relator. The Missouri Court of Appeals made permanent its writ of prohibition against the respondent circuit judge to bar any further action in the relator’s criminal action.
STATE OF MISSOURI EX REL. SARAH M. PRETTYMAN, Relator v. THE HONORABLE LYNETTE VEENSTRA, Respondent
Missouri Court of Appeals, Southern District - SD39402

Revocation of parole prohibited, related jail board bill unauthorized
Writs of prohibition issued “to avert the usurpation of power when a lower court lacks authority or jurisdiction[.]” Sentencing defendants to the custody of the Department of Corrections ended the authority of the circuit court and started the exclusive authority of the Department as to parole. The respondent circuit judge nevertheless issued a summons and a warrant, and confined the relator to jail. The Missouri Court of Appeals made permanent its writ of prohibition against the respondent circuit judge to bar any further action in the relator’s criminal action, except to tear up jail board bill for the relator’s unauthorized confinement.
STATE OF MISSOURI EX REL. BRANDON LEE RUTZ, Relator v. THE HONORABLE R. CRAIG CARTER, CIRCUIT JUDGE, Respondent
Missouri Court of Appeals, Southern District - SD39403

Elections

Secretary of State held in, then purged of, contempt
Civil contempt’s purpose was to encourage compliance with court orders by fine or commitment to jail. The elements of contempt included a court-ordered obligation and a breach of that obligation. In an action to determine which congressional redistricting map to use at the general election, old or new, the Supreme Court of Missouri required the use of the old map and barred the Missouri Secretary of State from “mandating the use of the” new map. The secretary emailed election authorities to mandate the use of a map three times: first, the old map; second, the new map; third, the old map. The second email put the secretary in contempt of court. A U.S. district court’s temporary restraining order did not change that result because that temporary restraining order did not require the second email and, even if it did, the U.S. Supreme Court stayed the temporary restraining order. The third email purged the secretary of contempt. Because the Missouri Secretary of State purged himself of contempt, the Supreme Court of Missouri did not order any commitment or fine.
Richard von Glahn, Appellant, v. Denny Hoskins, in His Official Capacity, et al., Respondents
Supreme Court of Missouri - SC101805

Family

Circuit court correctly characterized and awarded a non-existent asset
In actions for dissolution of marriage, circuit courts had to characterize and divide the parties’ assets. The source of funds determined whether assets, and increases in value, were subject to characterization as marital or separate assets. Assets subject to division were those existing on the date of trial, except that assets not existing on that date were also subject to division if secreted or squandered. Appellate courts could determine that circuit courts implicitly made findings of fact as to squandering and secreting assets from the circuit courts’ dispositions of assets. The record supported an implicit finding that the appellant tried to conceal an asset — by selling and deferring receipt of payment — in anticipation of dissolving the marriage, so the circuit court could characterize and divide that asset. And the appellant asked the circuit court to award an asset to a non-party so, if awarding that asset to the appellant was an error, the appellant invited that error. The Missouri Court of Appeals affirmed the judgment.
(Overview summary)
In RE The Marriage of: Andrew John Rottinghaus v. Kelly Ann Rottinghaus
Missouri Court of Appeals, Western District - WD88229

Workers’ compensation

Additional significant evidence doctrine was stricken under strict construction
Workers’ compensation statutes were subject to strict construction. Strict construction barred judicially created doctrines. Temporary awards were subject to modification pending final awards. Final awards were subject to the Labor and Industrial Relations Commission’s review. That review was de novo, so the judicially created requirement of “additional significant evidence” was not the standard for temporary or final awards. Final awards of the Commission only, not and ruling of an administrative law judge, were subject to judicial review. Judicial review included deference to findings of fact that had support in substantial and competent evidence on the whole record. The claimant had earlier work-related injuries for which the claimant received settlements and treatments. The claimant had a later injury that resulted in permanent partial disability and a temporary award. For the later injury, an administrative law judge’s award included amounts for a total knee replacement and future medical treatment. On review, the Commission denied those amounts in its award, finding less disability attributable to the later injury than the administrative law judge had. “The Commission is not bound by the experts' exact percentages of disability and is free to find a disability rating higher or lower than that expressed in medical testimony . . . because a claimant's degree of disability is not solely a medical question [, and] is a finding of fact within the special province of the commission.” The Missouri Court of Appeals affirmed the Commission’s award.
(Overview summary)
Gabriel Gilbert v. City of Grandview, MO
Missouri Court of Appeals, Western District - WD88375