Patrick S. Flynn, in his individual capacity, Appellant/Cross- Missouri Cases

Karla Allsberry, an elected circuit clerk, sought a declaration that Presiding Judge Patrick S. Flynn lacked authority to indefinitely suspend her and requested injunctive relief to be restored to her office. The circuit court declared Judge Flynn lacked such authority but denied injunctive relief, stating it could not enjoin another circuit judge. The Missouri Supreme Court affirmed the declaratory judgment, holding that an indefinite suspension constituted a de facto removal, which is beyond a presiding judge's administrative authority. The Court reversed the denial of injunctive relief, concluding that a circuit court has the power to grant injunctive relief against another circuit judge acting in an administrative capacity, and remanded the case for entry of the requested relief.