Patrick Starr, Maurice Charles, and Lee Francis Missouri Cases

Patrick Starr, Maurice Charles, and Lee Francis (Requestors) appealed a judgment in favor of the Jackson County Prosecuting Attorney (Prosecutor) in their lawsuit alleging violations of Missouri's Sunshine Law. The trial court granted judgment as a matter of law for the Prosecutor, finding Requestors failed to prove their records requests were received by the designated custodian of records. The appellate court affirmed, holding that Requestors did not establish the necessary element of receipt by the custodian, nor did they prove apparent authority or substantial compliance with the statute.