Missouri Court of Appeals, Western District / Jul 21, 2020
Aaron Malin vs. Missouri Association of Community Task Forces, D/B/A ACT Missouri
Aaron Malin sued ACT Missouri under the Missouri Sunshine Law, seeking records related to funding from the Missouri Department of Mental Health. The trial court granted summary judgment for ACT Missouri, denying Malin's request to defer ruling for discovery. The appellate court reversed and remanded, holding that the trial court erred by limiting its inquiry into ACT Missouri's "primary purpose" to its articles of incorporation and by denying discovery based on this erroneous premise. The court also clarified that a corporation organized under chapter 355 is not an "association" under a specific subsection of the Sunshine Law.