Missouri Court of Appeals, Eastern District / May 16, 2023
Herbert Morrison, Appellant, vs. Karen Goodwin, City Clerk for the City of Florissant, Missouri, Respondent.
Herbert Morrison appealed the dismissal of his action seeking to compel Florissant City Clerk Karen Goodwin to process his police misconduct complaints. Morrison argued that the trial court erred in dismissing his petition as moot and that the retrospective application of a new ordinance was unconstitutional. The Eastern District of the Missouri Court of Appeals dismissed the appeal, holding that the claim was moot because an amended city ordinance removed the city clerk's authority to receive or forward such complaints, rendering the requested relief impossible. The court further found that Morrison did not have a vested right to file complaints under the prior ordinances, thus the retrospective application was not unconstitutional.