Jennifer Henderson v. Business Loop Community Improvement District, Tom May and Carrie Gartner

CourtMissouri Court of Appeals
DecidedNovember 26, 2019
DocketWD82596
StatusPublished

This text of Jennifer Henderson v. Business Loop Community Improvement District, Tom May and Carrie Gartner (Jennifer Henderson v. Business Loop Community Improvement District, Tom May and Carrie Gartner) is published on Counsel Stack Legal Research, covering Missouri Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jennifer Henderson v. Business Loop Community Improvement District, Tom May and Carrie Gartner, (Mo. Ct. App. 2019).

Opinion

IN THE MISSOURI COURT OF APPEALS WESTERN DISTRICT JENNIFER HENDERSON, ) ) Appellant, ) ) v. ) WD82596 ) BUSINESS LOOP COMMUNITY ) Opinion filed: November 26, 2019 IMPROVEMENT DISTRICT, ) TOM MAY AND CARRIE GARTNER, ) ) Respondents. )

APPEAL FROM THE CIRCUIT COURT OF BOONE COUNTY, MISSOURI THE HONORABLE JODIE C. ASEL, JUDGE

Division One: Edward R. Ardini, Jr., Presiding Judge, Mark D. Pfeiffer, Judge and Cynthia L. Martin, Judge

Jennifer Henderson appeals the judgment of the Circuit Court of Boone County granting

Respondents’ Motion to Dismiss for Lack of Subject Matter Jurisdiction. Respondents are the

Business Loop Community Improvement District (“District”), District president Tom May, and

District executive director Carrie Gartner. The District held an election in 2015 asking registered

voters within its boundaries to authorize the imposition of a half-cent sales tax by District

businesses. The sales tax passed. Henderson—one of the individuals who voted against the tax—

initiated this action challenging the election, alleging “there were irregularities of sufficient

magnitude to cast doubt on the [election’s] validity” and seeking a judgment from the trial court declaring the election void as a result of these irregularities. Respondents moved to dismiss

Henderson’s claims, arguing the trial court lacked subject matter jurisdiction based on an absence

of statutory authority to hear a challenge to a community improvement district’s sales tax election.

The trial court granted the motion. Because we find that there is statutory authority for Henderson’s

election challenge, we reverse and remand.

Factual and Procedural Background1

The District—located in Boone County, Missouri—is a political subdivision of the State

of Missouri, organized under the Community Improvement District Act (“CID Act”), 2 sections

67.1401 to 67.1571.3 The Columbia City Council approved the creation of the District on April

20, 2015. The District is governed by a board of directors, and at the board’s first business meeting,

the directors agreed to seek voter approval of a half-cent sales tax to be imposed by businesses in

the District. Rather than have the election conducted by the Boone County Clerk’s office, which

is the county’s election authority, the District chose to conduct the sales tax election itself.

On December 1, 2015, the District announced on its website that the sales tax election

would be held on December 10, 2015, and sent mail-in ballots to qualified voters.4 Voters were

1 Because this is an appeal from the trial court’s granting of a motion to dismiss, “we will assume that all of the factual averments [in Henderson’s petition] are true and will make all reasonable inferences in [Henderson’s] favor.” See Miller v. Frank, 519 S.W.3d 472, 475 (Mo. App. E.D. 2017). 2 “Generally, the CID Act provides for property owners or business owners within a specified area to form either a not-for-profit corporation or a political subdivision.” Joseph G. Lauber, Public-Private Partnership in Community Development: Applying Constitutional Standards for Implementing the Missouri Community Improvement District Act, 59 Journal of the Missouri Bar 80, 80 (2003). “Once formed, these entities possess powers enabling them to carry out numerous fiscal initiatives, primarily the ability to raise funds through special assessments and taxes for the provision of public infrastructure.” Id. 3 All statutory references are to RSMo Supp. 2014. 4 For purposes of sales tax elections under the CID Act, “[q]ualified voters” are “[r]egistered voters” or “[i]f no registered voters reside in the district, the owners of one or more parcels of real property located within the district[.]” § 67.1401.2(14)(b). “Registered voters” are “persons who reside within the district and who are qualified and registered to vote pursuant to chapter 115, pursuant to the records of the election authority as of the thirtieth day prior to the date of the applicable election.” § 67.1401.2(15). There were fourteen registered voters residing in the District during the time period relevant to this election.

2 instructed to return the completed ballot by December 10, 2015, and that they could do so by

mailing or hand-delivering the ballot to the District’s office. Voters were required to print and sign

their names and include their addresses on the ballot itself.5 The District hired four election judges

to observe the counting of the ballots; two were affiliated with the Democratic Party and two were

affiliated with the Republican Party.

Prior to and at the time of the election, Henderson was a registered voter living within the

District’s boundaries. At approximately 2:00 p.m. on December 10th, Henderson and another

registered voter went to the District’s office to cast their ballots. Respondent Gartner greeted them

and retrieved an unsecured file box from behind a wall that separated the District’s office lobby

from other parts of the office. Gartner opened the box’s lid and invited them to drop their ballots

into the box, which they did. Approximately six hours later, District officials announced that the

sales tax had passed by a vote of 4 to 3. Henderson was one of the three individuals who had voted

against the sales tax.

On December 14th, the District reported the results of the vote to the Missouri Department

of Revenue, as required by section 67.1545.3. Collection of the sales tax began in April 2016. See

§ 67.1545.3 (“The sales and use tax authorized by this section shall become effective on the first

day of the second calendar quarter after the director of the department of revenue receives notice

of the adoption of such tax.”).

On January 8, 2016, Henderson filed a two-count petition against the District, Gartner, and

May. In Count I, Henderson alleged that the District’s election failed to comply with the Missouri

5 Above the signature, printed name, and address lines, the ballot provided that “[b]y submitting this Ballot to the [District], the undersigned hereby certifies, represents, and warrants that the undersigned is a person who resides within the [District] and who is qualified and registered to vote pursuant to Chapter 115 of the Missouri Revised Statutes.”

3 Constitution in four respects: (1) lack of a secret ballot; (2) lack of a secured ballot box; (3) lack

of sufficient notice of the election; and (4) lack of a neutral administrator. Henderson alleged that

these “Constitutional irregularities” were of “sufficient magnitude to cast doubt on the validity of

the election,” justifying a new election pursuant to section 115.593. 6 She requested that the trial

court issue an order commanding that the District fix these deficiencies in “any subsequent

election.”

In Count II, Henderson sought a judgment from the trial court declaring: (1) the District’s

election was void because of the irregularities described in Count I; (2) no sales tax may be

collected as a result of the election; (3) the District and its officials knowingly, purposefully, and

intentionally conducted an irregular election that did not comply with Missouri law; (4) to the

extent that section 67.1541 authorizes the election to be conducted as it was, the statute is

unconstitutional as applied to the facts of this case; and (5) Henderson is entitled to recover her

costs and attorneys’ fees.

Respondents filed a Motion to Dismiss for Lack of Subject Matter Jurisdiction, in which

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Bluebook (online)
Jennifer Henderson v. Business Loop Community Improvement District, Tom May and Carrie Gartner, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jennifer-henderson-v-business-loop-community-improvement-district-tom-may-moctapp-2019.