Karen Coburn v. Kramer & Frank, P.C.

CourtMissouri Court of Appeals
DecidedMarch 9, 2021
DocketED108948
StatusPublished

This text of Karen Coburn v. Kramer & Frank, P.C. (Karen Coburn v. Kramer & Frank, P.C.) 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
Karen Coburn v. Kramer & Frank, P.C., (Mo. Ct. App. 2021).

Opinion

In the Missouri Court of Appeals Eastern District DIVISION ONE

KAREN COBURN, ) No. ED108948 ) Appellant, ) Appeal from the Circuit Court of ) the City of St. Louis vs. ) Cause No. 1922-CC0922 ) ) Honorable Michael F. Stelzer KRAMER & FRANK, P.C., ) ) Respondent. ) Filed: March 9, 2021

Karen Coburn (“Coburn” or “Appellant”) appeals the circuit court’s judgment granting

Kramer & Frank, P.C.’s (“Kramer & Frank” or “Respondent”) Motion for Judgment on the

Pleadings. Appellant raises one point on appeal, arguing that the circuit court erred in granting

Respondent’s Motion for Judgment on the Pleadings because no order specifically appointing the

special process server who served her with the summons and petition in the underlying collection

lawsuit was entered by the circuit court or the circuit clerk, and thus, the default judgment

entered against her in the underlying collection lawsuit was void as a matter of law for lack of

personal jurisdiction. Appellant also argues that she has stated claims for violations of the

Missouri Merchandising Practices Act and for unjust enrichment.

We affirm. I. Factual and Procedural Background

Coburn’s Class Action Lawsuit against Kramer & Frank

On May 6, 2019, Coburn commenced this lawsuit in the Circuit Court of the City of St.

Louis by filing her two-count Class Action Petition against Kramer & Frank, a “collection law

firm” in Missouri (the “Class Action Case”). On behalf of herself and a group of similarly-

situated individuals, Coburn asserts violations of the Missouri Merchandising Practices Act

(§ 407.0101 et seq.) (the “MMPA”) and a claim for unjust enrichment arising from Kramer &

Frank’s alleged “misuse of court process to obtain default judgments against Coburn and over

100 putative class members.”

At the core of her MMPA and unjust enrichment claims, Coburn alleges that Kramer &

Frank, on behalf of its clients, obtained default judgments in certain collection lawsuits without

first obtaining personal jurisdiction because the person who served her (and the other putative

class plaintiffs) in these lawsuits was not properly appointed by the circuit court or the court

clerk to serve process “as required by law,” rendering the judgments void.2 Specifically, in her

MMPA claim, Coburn alleges that Kramer & Frank “engaged in deceptive and/or unfair

practices … by taking default judgments against Coburn and the putative class members” in that

“Kramer & Frank had not acquired personal jurisdiction over Coburn and the putative class

members.” In her unjust enrichment claim, she similarly alleges that “[i]t would be unjust to

allow Kramer & Frank to retain the benefit of the default judgments and/or monies collected

after said judgments were entered from Coburn and the putative class members because it

1 All statutory references are to Mo. Rev. Stat. Cum. Supp. 2019, unless otherwise indicated. 2 Although the Class Action Petition itself does not explain the specific basis upon which Coburn believed the process servers were not properly “appointed” in accordance with applicable law, in her subsequent briefing on Kramer & Frank’s Motion for Judgment on the Pleadings, she further explains that the process servers were not properly “appointed” because neither the circuit court nor the circuit clerk entered an order in the cases expressly approving the requested special process servers, which she maintains is required under §§ 506.140 and 506.180.

2 received these benefits under the guise that Missouri courts had personal jurisdiction over

Coburn and the putative class members when personal jurisdiction did not exist.”

On these grounds, the Class Action Petition seeks class certification and that Coburn be

appointed as class representative, as well as requests all available damages, attorneys’ fees, costs,

and pre- and post-judgment interest. More importantly, in both her MMPA and unjust

enrichment claims, Coburn also requests the following specific relief: “[A]n order or judgment

declaring that the judgments entered against Karen Coburn and the class members are void as a

matter of law and ordering Kramer & Frank to set aside all such judgments.”3

The Underlying Collection Lawsuit 4

On April 14, 2014, Kramer & Frank, on behalf of its client Metropolitan Sewer District

(“MSD”), commenced the underlying collection lawsuit against Coburn in the Circuit Court of

the City of St. Louis, Associate Division (the “Collection Case”). In the Collection Case, MSD

alleged that Coburn owed it a debt of $571.80 for overdue wastewater and stormwater charges

levied pursuant to MSD Ordinances 13405 and 13466.

On April 14, 2014, Kramer & Frank, on behalf of MSD, filed a request to appoint Amy

Post (“Post”) as special process server in the Collection Case (the “SPS Request”). 5 The SPS

3 We note that Kramer & Frank could not be ordered to set aside the default judgments, as only the trial court could actually set aside the Default Judgment. See Rule 74.06(b) (“On motion and upon such terms as are just, the court may relieve a party or his legal representative from a final judgment or order…” (emphasis added)); see also Rule 74.06(d) (“This Rule 74.06 does not limit the power of the court to entertain an independent action to relieve a party from a judgment or order or to set aside a judgment for fraud upon the court.” (emphasis added)). 4 To the extent necessary, we have reviewed the pleadings and other filings in the underlying collection lawsuit and have taken judicial notice thereof, which we are permitted to do when the other court records are interwoven with the case sub judice, as they are in this case. Branch v. State, 531 S.W.3d 621, 623-24 (Mo. App. E.D. 2017); Envtl. Utils., LLC v. Public Serv. Comm’n, 219 S.W.3d 256, 265 (Mo. App. W.D. 2007). 5 As explained in Footnote 14, even though MSD denominated this request as a “motion,” we find that it was actually a request pursuant to § 506.140.1, which either the circuit court or circuit clerk could grant, notwithstanding § 506.050.

3 Request appears to be the only such request filed in the Collection Case, and thus, it does not

appear that MSD requested the appointment of anyone other than Post as special process server.

Pursuant to the Local Rule 14.16, “[a]ny person appointed by the Court or the Circuit

Clerk to serve process must have a license issued pursuant to this rule to serve process.”

Furthermore, “[t]he Sheriff of the City of St. Louis shall maintain a list of persons licensed to

serve process pursuant to this rule, and shall make such list available to litigants upon request.”

Local Rule 14.4. In addition, the Local Rule regarding applications to become a special process

server provides as follows: “Applications for the appointment of a special process server shall be

made on forms available in the offices of the Sheriff and Circuit Clerk. Orders [a]ppointing

special process servers may list more than one licensed server as alternatives.” Local Rule 14.9.

Although the record does not contain conclusive evidence in this regard, it appears that Post was

on the list of licensed process servers maintained by the Sheriff of the City of St. Louis at the

time MSD filed the SPS Request in the Collection Case.

Although the SPS Request contained a signature line for the trial judge to sign, no signed

copy of the same appears in the court’s file in the Collection Case. However, a docket entry was

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