City of Kansas City, Missouri v. Karen Chastain

CourtSupreme Court of Missouri
DecidedFebruary 4, 2014
DocketSC93195
StatusPublished

This text of City of Kansas City, Missouri v. Karen Chastain (City of Kansas City, Missouri v. Karen Chastain) is published on Counsel Stack Legal Research, covering Supreme Court of Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
City of Kansas City, Missouri v. Karen Chastain, (Mo. 2014).

Opinion

SUPREME COURT OF MISSOURI en banc

City of Kansas City, Missouri, ) ) Respondent, ) ) vs. ) No. SC93195 ) Karen Chastain, et al., ) ) Appellants. )

Appeal from the Circuit Court of Jackson County, Missouri Honorable Sandra C. Midkiff, Judge

Opinion issued February 4, 2014

Karen Chastain and additional members of a “Committee of Petitioners”

(collectively, “Chastain”) appeal a judgment declaring that a proposed ordinance

initiative petition violates article III, section 51 of the Missouri Constitution because the

initiative was used for the appropriation of money. Chastain also appeals the dismissal of

her counterclaim for mandamus.

The proposed ordinance does not appropriate money and, therefore, does not

violate article III, section 51 of the Missouri Constitution. The judgment is reversed, and

the case is remanded. Facts

Kansas City is a constitutional charter city that permits citizens to propose

ordinances via initiative petition. See Chastain v. City of Kansas City, 289 S.W.3d 759,

761 (Mo. App. 2009). In July 2011, Chastain submitted to the city clerk an initiative

petition seeking adoption of an ordinance that would impose additional sales taxes “for

the benefit of the city.”

The preamble to the proposed ordinance states that the purpose of the sales taxes is

to construct a light rail system. The proposed ballot title suggests using the revenues to

construct infrastructure for a light rail system, a street car, electric shuttle buses and

bicycles. The only action mandated by the proposed ordinance is the imposition of two

taxes: (1) a 1/4 of one percent sales tax for capital improvements as authorized in sections

94.575 to 95.577 and (2) a 1/8 of one percent sales tax for transportation purposes as

authorized in sections 94.600 to 94.655. 1 Although the taxes are imposed for “capital

improvements” and “transportation purposes,” no particular project is mandated.

The proposed ordinance was referred to the city council’s transportation and

infrastructure committee. The committee held a public hearing and sent the ordinance to

the city council with a recommendation that the council not pass the ordinance. The city

council determined that the city was not required to place the election before the voters.

Chastain filed a request with the city clerk to place the ordinance on the ballot. The city

declined.

The city filed a petition for a declaratory judgment seeking a declaration that the

proposed ordinance was facially unconstitutional pursuant to article III, section 51 of the Missouri Constitution because the ordinance failed to provide the revenue necessary to

construct the transportation system. Chastain filed a counterclaim seeking mandamus to

require the city to put the proposed ordinance to a public vote.

The trial court entered an order sustaining the city’s motion to dismiss Chastain’s

counterclaim. Subsequently, the trial court entered final judgment for the city on grounds

that the proposed ordinance was “an unconstitutional appropriation ordinance under

Article III, section 51 of the Missouri Constitution.” The judgment then concluded that

the “City is therefore not obligated to place the facially unconstitutional ordinance before

the voters, and is legally justified in refusing to place said ordinance before the voters.”

Chastain raises five points on appeal: (1) that the trial court erred in concluding

that the ordinance was facially unconstitutional because insufficient revenue is not

grounds for pre-election review of an initiative petition; (2) that the trial court erred in

declaring the proposed ordinance to be a facially unconstitutional appropriation

ordinance; (3) that the trial court lacked subject matter jurisdiction because the city failed

to prove that it lacked an adequate remedy at law; (4) that the trial court erred in

dismissing her counterclaim for mandamus because the ordinance was not facially

unconstitutional; and (5) that the trial court erred in the admission of certain evidence at

the evidentiary hearing.

Standard of Review

“The standard of review in a declaratory judgment case is the same as in any other

court-tried case.” Levinson v. State, 104 S.W.3d 409, 411 (Mo. banc 2003). “The

judgment will be affirmed unless there is no substantial evidence to support it, it is

3 against the weight of the evidence, or it erroneously declares or applies the law.” Id. In

this case, the dispositive issue is whether the proposed ordinances violate the Missouri

Constitution. This is a legal question subject to de novo review. See, Pearson v. Koster,

367 S.W.3d 36, 43 (Mo. banc 2012)(legal question in a court-tried case is subject to de

novo review).

Pre-election review of initiative petitions

Chastain’s first point asserts the trial court erred by conducting pre-election review

of the facial constitutionality of the proposed ordinance. This point fails because

Missouri law authorizes courts to conduct pre-election review of the facial

constitutionality of an initiative petition. See Missourians to Protect the Initiative

Process v. Blunt, 799 S.W.2d 824, 828 (Mo. banc 1990); Kansas City v. McGee, 269

S.W.2d 662, 664 (Mo. 1954)(courts may review a law to be enacted by initiative to

determine its constitutionality). The idea underlying this rule is that pre-election review

of the facial constitutionality of an initiative petition is warranted given the “cost and

energy expended relating to elections” and to avoid the “public confusion generated by

avoiding a speedy resolution of a question ….” Blunt, 799 S.W.2d at 828. The circuit

court had the authority to engage in pre-election review of the facial constitutionality of

the initiative petition.

Availability of declaratory relief

Chastain asserts that the trial court lacked subject matter jurisdiction to consider

the city’s petition for declaratory judgment because the city failed to prove that it lacked

an adequate remedy at law. There is no doubt that the trial court had subject matter

4 jurisdiction. See J.C.W. ex rel. Webb v. Wyciskalla, 275 S.W.3d 249, 253 (Mo. banc

2009)(subject matter jurisdiction is a matter of “the court’s authority to render a judgment

in a particular category of case”). Circuit courts have subject matter jurisdiction to enter

declaratory judgments.

The lack of an adequate remedy at law is a prerequisite to relief via declaratory

judgment. See State ex rel. SLAH, L.L.C. v. City of Woodson Terrace, 378 S.W.3d 357,

361 (Mo. banc 2012). As such, the real issue presented by Chastain’s third point is

whether the trial court erred in concluding that the city lacked an adequate legal remedy.

Chastain asserts that if the ordinance was placed before the voters and passed, then

the city’s adequate legal remedy is to repeal the ordinance as it is empowered to do

pursuant to the city charter.

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Related

State Ex Rel. Chastain v. City of Kansas City
289 S.W.3d 759 (Missouri Court of Appeals, 2009)
J.C.W. Ex Rel. Webb v. Wyciskalla
275 S.W.3d 249 (Supreme Court of Missouri, 2009)
Lincoln Credit Co. v. Peach
636 S.W.2d 31 (Supreme Court of Missouri, 1982)
Kansas City v. McGee
269 S.W.2d 662 (Supreme Court of Missouri, 1954)
State Ex Rel. Powers v. Donohue
368 S.W.2d 432 (Supreme Court of Missouri, 1963)
Levinson v. State
104 S.W.3d 409 (Supreme Court of Missouri, 2003)
State Ex Rel. Petti v. Goodwin-Raftery
190 S.W.3d 501 (Missouri Court of Appeals, 2006)
Independence-National Education Ass'n v. Independence School District
223 S.W.3d 131 (Supreme Court of Missouri, 2007)
Missourians to Protect the Initiative Process v. Blunt
799 S.W.2d 824 (Supreme Court of Missouri, 1990)
State Ex Rel. Carpenter v. City of St. Louis
2 S.W.2d 713 (Supreme Court of Missouri, 1928)
City of Springfield v. Clouse
206 S.W.2d 539 (Supreme Court of Missouri, 1947)
Sanders v. City of St. Louis
303 S.W.2d 925 (Supreme Court of Missouri, 1957)
Pearson v. Koster
367 S.W.3d 36 (Supreme Court of Missouri, 2012)
State ex rel. Slah, L.L.C. v. City of Woodson Terrace
378 S.W.3d 357 (Supreme Court of Missouri, 2012)

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