City of St. Peters Missouri Cases

The City of St. Peters appealed the trial court's dismissal of 31 municipal ordinance violation citations against Collene Velma Lienemann for property maintenance and nuisance issues. The appellate court first determined that while the City's initial notices of appeal were untimely, it properly exercised its discretion to allow a late filing. The court then reversed the dismissal, holding that further factual determinations were needed to establish Lienemann's liability as a proper defendant under the City's ordinances, which depend on her level of "control" or "responsibility" for the property. Finally, the court denied the City's argument that collateral estoppel applied, as it is generally unavailable to the State in quasi-criminal municipal proceedings.

Amanda Gill appealed the circuit court's dismissal of Count II of her petition, which alleged sex discrimination under the Missouri Human Rights Act (MHRA) based on a disparate impact theory. The circuit court dismissed the claim, finding it time-barred and that Missouri courts do not recognize a disparate impact claim under the MHRA. The appellate court affirmed the dismissal, holding that Gill's claim was time-barred as her transfer was a discrete act not subject to the continuing violation theory, and that the Lilly Ledbetter Act does not extend MHRA filing periods. The court further held that Missouri courts have not recognized a disparate impact claim under the MHRA, and Gill failed to plead facts to support such a claim.

Patricia Watson sued the City of St. Peters for negligence after she was injured when her bicycle wheel entered a storm water sump inlet extending into a sidewalk. The jury found for the City, and the trial court entered judgment accordingly. The appellate court reversed and remanded for a new trial, holding that the trial court abused its discretion by excluding evidence of the City's pre-accident citywide program to address sump inlet conditions. This evidence was not excludable as a subsequent remedial measure and was material to proving the City's knowledge of the dangerous condition.