City of Normandy, et al. Missouri Cases

The state appealed the circuit court's denial of its motion for relief from a permanent injunction, which had prevented the enforcement of statutes previously declared unconstitutional in "City of Normandy I." The state argued that a subsequent change in decisional law, established in "City of Aurora," rendered the statutes constitutional and made the injunction inequitable under Rule 74.06(b)(5). The Missouri Supreme Court affirmed the circuit court's judgment, holding that a change in decisional law is neither necessary nor sufficient for Rule 74.06(b)(5) relief, and that the circuit court did not abuse its discretion in weighing the equities.

The City of Normandy and other municipalities appealed the circuit court's decision to grant the state relief from a 2016 permanent injunction. The injunction had prevented the state from enforcing sections 67.287 and 479.359.2, which were found to be unconstitutional special laws. The state sought relief under Rule 74.06(b)(5) after the Missouri Supreme Court restored the rational basis analysis for special laws in a subsequent case. The Supreme Court vacated the circuit court's judgment and remanded for further proceedings, holding that a change in decisional law alone is not sufficient to warrant relief from judgment under Rule 74.06(b)(5), and the circuit court failed to properly weigh the equities.