Missouri Court of Appeals, Western District / Feb 13, 2019
Russell Scott Lynch vs. James Hurley
Russell Scott Lynch appealed the dismissal of his petition for declaratory judgment, seeking credit against his St. Charles County sentences for time spent in St. Louis County jail and in a long-term treatment program. The trial court dismissed the claim for jail time credit based on collateral estoppel from a prior habeas judgment and dismissed the treatment program credit claim for failure to state a claim. The appellate court affirmed the dismissal regarding the treatment program credit but reversed and remanded the jail time credit claim, holding that the habeas court's ruling on the merits of a non-cognizable claim had no preclusive effect.