Case summaries for Sept. 11-17, 2026

Appellate | ADR | Criminal | Post-conviction | Probate

Appellate

Wrong reason, right result
An appellate court “will affirm the circuit court’s judgment ‘if it is correct on any ground supported by the record regardless of whether the circuit court relied upon it.’” The petitioner sought an exemption from registration as a sex offender, and the circuit court dismissed the action for lack of jurisdiction. That reasoning was erroneous because the constitution gave circuit courts jurisdiction over all matters civil and criminal. But the result was correct because statutes provided the conditions for that relief and the appellant did not meet those conditions. The Missouri Court of Appeals affirmed the judgment of dismissal.
(Overview summary)
Sherma Johnson, Appellant, v. Missouri State Highway Patrol, et al., Respondents
Missouri Court of Appeals, Eastern District - ED113828

Judgment was not final without resolving all claims
Appellate jurisdiction was a matter of statute and rule, not “waiver, acquiescence, or even express consent[.]” For the parties’ action, a final judgment was necessary before appellate jurisdiction was possible. The judgment was not final because it failed to address all the petition’s claims. Nevertheless, the Missouri Court of Appeals issued an opinion on the judgment in an earlier appeal. The law of the case doctrine was discretionary when an earlier opinion “arose from mistake or resulted in a manifest injustice” to the defendant. “Under these exceptional circumstances, we exercise our discretion not to apply the law of the case doctrine.” The Court of Appeals recalled its mandate and withdrew its opinion in the earlier appeal, which reversed the judgment issued pursuant to that earlier appeal and mooted the remaining matters on appeal, and it remanded the action for a final judgment.
(Overview summary)
Matthew Valdivia v. Missouri Department of Corrections
Missouri Court of Appeals, Western District - WD88465

ADR

No contract, no arbitration agreement
Arbitration was a matter of contract. Contracts existed only when essential terms were agreed. Negotiations over contract terms did not constitute a contract. The parties agreed to arbitrate disputes arising from a prospective employment contract. “The only legally enforceable promise created out of at-will employment is the employer’s promise to pay the employee for the work he or she performs.” Therefore, essential terms of a contract for at-will employment included the start date. No start date was ever agreed, and the employer withdrew its offer of employment before employment started. Without a contract of employment, there was no arbitration agreement. The circuit court denied the employer’s motion to compel arbitration, and the Missouri Court of Appeals affirmed that ruling.
(Overview summary)
Jeremy Bredwell v. Snap-On Incorporated, et al.
Missouri Court of Appeals, Western District - WD88325

Criminal

Self-defense theories had to be in disjunctive
Counsel affirmatively stating “no objection” to the State’s proffered instruction did not waive plain error review. Self-defense was a special negative defense, meaning that the defendant had to raise it and the State had to disprove it, like an extra element of the offense. The defendant raised general self-defense and castle doctrine self-defense, so the State had to disprove both. But the instructions allowed conviction if the State negated either general self-defense “or” castle doctrine self-defense. That lowered the State’s burden of proof and constituted plain error. The Missouri Court of Appeals reversed the convictions and remanded the action for a new trial.
(Overview summary)
State of Missouri v. Robert E. Matlock, Jr.
Missouri Court of Appeals, Western District - WD87929

Post-conviction

Findings of fact and conclusions of law required on timeliness.
Circuit courts had to make findings of fact and conclusions of law on the timeliness of initial motions, and a motion to amend was not necessary to preserve that matter. Failure to make those findings and conclusions made no record for appellate review and therefore required a remand. The movant’s motion arrived late, but the movant alleged timely filing and alternatives to that requirement. The circuit court made no findings of fact on the matter of timeliness, so the Missouri Court of Appeals remanded the action to the circuit court.
(Overview summary)
Joshua C. Proffer, Appellant, v. State of Missouri, Respondent
Missouri Court of Appeals, Eastern District - ED114132

Probate

Non-probate transfer was non-recoverable
When a decedent’s liabilities were greater than the decedent’s estate, an action for accounting could re-capture “recoverable transfers,” meaning decedent property that a creditor could have seized and attached for the decedent’s debts. That did not describe a decedent’s individual retirement account because all amounts disbursed from such accounts to the account holder or a beneficiary were exempt from attachment and execution. A beneficiary of the decedent’s individual retirement account received their benefit and the estate’s personal representative brought an action for accounting to recover that transfer. The circuit court denied relief and the Missouri Court of Appeals affirmed that judgment.
(Overview summary)
In the Estate of: Dennis Hicks
Missouri Court of Appeals, Eastern District - ED114395

Approval of final settlement affirmed
In an earlier appeal, the appellant challenged the circuit court’s order approving the sale of assets. The protectee’s death ended the respondent conservator’s authority over the protectee's assets except for winding up and making a final settlement. Final settlements did not dispose of all assets; they accounted for all assets. That accounting did not have to disclose that the former conservator participated in the auction. The only person who had standing to raise a conflict of interest objection was the personal representative of the decedent’s estate. The appellant did not show that any assets were sold at less than fair market value so the circuit court approved the settlement. When the appellant appealed, law of the case barred the appellant from raising an argument that the appellant could have raised in the earlier appeal. The Missouri Court of Appeals affirmed the order approving the final settlement.
IN THE MATTER OF KYONG SPRUILL, INCAPACITATED AND DISABLED. J-PIA SPRUILL, Respondent v. ARTHUR J. SPRUILL, Appellant
Missouri Court of Appeals, Southern District - SD39185