City of St. Louis; St. Louis County; and Jackson County v. State of Missouri; and Eric Schmitt, Attorney General of Missouri

CourtSupreme Court of Missouri
DecidedApril 26, 2022
DocketSC99290
StatusPublished

This text of City of St. Louis; St. Louis County; and Jackson County v. State of Missouri; and Eric Schmitt, Attorney General of Missouri (City of St. Louis; St. Louis County; and Jackson County v. State of Missouri; and Eric Schmitt, Attorney General of Missouri) 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 St. Louis; St. Louis County; and Jackson County v. State of Missouri; and Eric Schmitt, Attorney General of Missouri, (Mo. 2022).

Opinion

SUPREME COURT OF MISSOURI en banc CITY OF ST. LOUIS; ST. LOUIS COUNTY; ) Opinion issued April 26, 2022 AND JACKSON COUNTY, ) ) Appellants, ) ) v. ) No. SC99290 ) STATE OF MISSOURI; AND ) ERIC SCHMITT, ATTORNEY GENERAL ) OF MISSOURI, ) ) Respondents. )

APPEAL FROM THE CIRCUIT COURT OF COLE COUNTY The Honorable Daniel R. Green, Judge

The City of St. Louis, St. Louis County, and Jackson County (hereinafter and

collectively, “Plaintiffs”) filed a declaratory judgment action seeking a declaration that the

Second Amendment Preservation Act (hereinafter “SAPA”), codified in sections 1.410

through 1.485,1 is unconstitutional and requesting injunctive relief. The state moved for

judgment on the pleadings, alleging Plaintiffs had adequate remedies at law rendering a

declaratory judgment improper and, alternatively, defending SAPA’s constitutional

validity. The circuit court sustained the state’s motion for judgment on the pleadings,

1 All statutory references to SAPA are to RSMo Supp. 2021. finding Plaintiffs had an adequate remedy at law because multiple, individual lawsuits are

pending in which Plaintiffs could assert their constitutional challenges. Plaintiffs appealed

to this Court. 2

This Court holds Plaintiffs met their burden of demonstrating they are entitled to

proceed with a declaratory judgment action because they lack an adequate remedy at law

in which to adjudicate their specific constitutional challenges. Because Plaintiffs failed to

file a dispositive pleading and the circuit court did not have the opportunity to adjudicate

their constitutional challenges or claims for injunctive relief in the first instance, this Court

declines to enter judgment pursuant to Rule 84.14. The circuit court’s judgment is

reversed, and the cause is remanded for further proceedings consistent with this opinion.

Factual and Procedural Background

In 2021, the General Assembly passed House Bills Nos. 85 and 310, collectively

known as SAPA, which repealed section 1.320, RSMo 2016, and enacted “in lieu thereof

nine new sections relating to the sole purpose of adding additional protections to the right

to bear arms, with penalty provisions and an emergency clause.” 2021 Mo. Legis. Serv.

H.B. 85 & 310. These provisions were codified in sections 1.410 through 1.485.

SAPA’s first four sections contain legislative findings and declarations. In

particular, section 1.410 contains ten legislative findings and declarations concerning the

relationship between the federal government and its federal acts, laws, executive orders,

2 This Court has exclusive jurisdiction over an appeal involving the constitutional validity of a statute. Mo. Const. art. V, sec. 3.

2 administrative orders, rules, and regulations (hereinafter and collectively, “federal gun

laws”) and the state as they impact Missouri’s law-abiding citizens’ right to keep and bear

arms. Section 1.420 declares certain federal gun laws “shall be considered infringements

on the people’s right to keep and bear arms” in Missouri. Section 1.430 states all federal

gun laws “that infringe upon the people’s right to keep and bear arms … shall not be

recognized by this state, shall be specifically rejected by this state, and shall not be enforced

by this state.” Section 1.440 directs Missouri courts and law enforcement agencies to

“protect the rights of law-abiding citizens to keep and bear arms” within Missouri “and to

protect these rights from infringement as defined under section 1.420.”

SAPA’s five remaining sections comprise the substantive provisions to enforce

these legislative declarations. Section 1.450 removes from Missouri entities, persons,

public officers, state employees, and political subdivisions “the authority to enforce or

attempt to enforce any” federal gun law “infringing on the right to keep and bear arms as

described under section 1.420.” However, nothing in SAPA “shall be construed to prohibit

Missouri officials from accepting aid from federal officials in an effort to enforce Missouri

laws.” Id. Sections 1.460 and 1.470 impose civil liability on state political subdivisions

and law enforcement agencies that employ individuals who knowingly violate “section

1.450 or otherwise knowingly deprive[]” Missouri citizens of their rights to keep and bear

arms. Specifically, these actors “shall be liable to the injured party in an action at law, suit

in equity, or other proper proceeding for redress, and subject to a civil penalty of fifty

thousand dollars per occurrence.” Section 1.460.1. Moreover, any state “political

subdivision or law enforcement agency that knowingly employs an individual acting or

3 who previously acted as an official, agent, employee, or deputy of the government of the

United States, or otherwise acted under the color of federal law within [Missouri], who has

knowingly” either “[e]nforced or attempted to enforce any of the infringements identified

in section 1.420” or “[g]iven material aid and support to the efforts of another who enforces

or attempts to enforce any of the infringements identified in section 1.420” is likewise

“subject to a civil penalty of fifty thousand dollars per employee hired by the political

subdivision or law enforcement agency.” Section 1.470.1(1)-(2). Section 1.480.1 defines

a “law abiding citizen.” Section 1.480.2 sets forth what actions constitute “material aid

and support.” Subsections (3) and (4) of section 1.480 enumerate exceptions in which

providing material aid and support will not constitute a SAPA violation. Section 1.480.5

provides SAPA “shall be applicable to offenses occurring on or after August 28, 2021.”

Section 1.485 contains a severability clause.

In June 2021, shortly after the governor signed SAPA into law, the City of St. Louis

and St. Louis County filed a declaratory judgment action seeking to declare SAPA

unconstitutional and moved for a preliminary injunction to prevent SAPA from being

enforced while the litigation was pending. The declaratory judgment petition subsequently

was amended to add Jackson County as an additional plaintiff. Plaintiffs’ petition alleged

SAPA infringed upon rights guaranteed by the state and federal constitutions, curtailed

law enforcement officers’ ability to investigate, apprehend, and prosecute criminals: and

violated the United States Supremacy Clause. The petition further claimed SAPA violated

the Missouri Constitution because it: usurped the power and authority granted to charter

cities and counties; did not having a single subject, clear title, or original purpose; created

4 a special law; and infringed upon the separation of powers. The petition stated, because

SAPA did not identify specific federal gun laws it deemed unconstitutional, Plaintiffs

“were in doubt concerning their rights, duties, and liabilities” under SAPA regarding which

federal gun laws could not be enforced. Because sections 1.420 and 1.450 were vague and

indefinite, Plaintiffs maintained they “were in doubt concerning their potential liability”

under sections 1.460 and 1.470. Plaintiffs alleged, because they employed and continued

to employ law enforcement officers who have or will undertake to enforce federal gun

laws, they were at risk for civil penalties. Plaintiffs’ petition set forth instances in which

SAPA enforcement would be “almost assuredly disastrous” with respect to participating in

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City of St. Louis; St. Louis County; and Jackson County v. State of Missouri; and Eric Schmitt, Attorney General of Missouri, Counsel Stack Legal Research, https://law.counselstack.com/opinion/city-of-st-louis-st-louis-county-and-jackson-county-v-state-of-mo-2022.