JOHNNIE SMITH and SHARON SMITH Missouri Cases

Farm Bureau New Horizons Insurance Company of Missouri appealed the trial court's order granting Johnnie and Sharon Smith's motion for a new trial. The Smiths' house and car were destroyed by fire, and Farm Bureau denied coverage, alleging arson. After a jury verdict for Farm Bureau, the trial court granted a new trial without specifying the grounds. The appellate court reversed, holding that the trial court's order was presumptively erroneous under Rule 84.05(c) for failing to specify grounds, and the Smiths failed to demonstrate an adequate, nondiscretionary ground to overcome this presumption.