Linda A. Holding v. Kansas City Area Transportation Authority

CourtMissouri Court of Appeals
DecidedAugust 27, 2019
DocketWD82064
StatusPublished

This text of Linda A. Holding v. Kansas City Area Transportation Authority (Linda A. Holding v. Kansas City Area Transportation Authority) 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
Linda A. Holding v. Kansas City Area Transportation Authority, (Mo. Ct. App. 2019).

Opinion

IN THE MISSOURI COURT OF APPEALS WESTERN DISTRICT LINDA A. HOLDING, ) Appellant, ) ) v. ) WD82064 ) KANSAS CITY AREA ) FILED: August 27, 2019 TRANSPORTATION ) AUTHORITY, ) Respondent. ) Appeal from the Circuit Court of Jackson County The Honorable Kevin D. Harrell, Judge Before Division One: Cynthia L. Martin, P.J., and Victor C. Howard and Alok Ahuja, JJ. Linda Holding sued the Kansas City Area Transportation Authority

(“KCATA”) in the Circuit Court of Jackson County. She alleged that on three

separate occasions when she was traveling as a passenger on KCATA buses, she

suffered injuries as a result of the negligence of the bus drivers. The case was tried,

and a jury returned a verdict for KCATA. The circuit court entered judgment

accordingly. Holding appeals. Because of the significant deficiencies in Holding’s

briefing, and her failure to provide an adequate record, we dismiss Holding’s appeal.

Analysis The requirements for appellate briefing are set forth in Rule 84.04.

“Compliance with Rule 84.04 briefing requirements is mandatory in order to ensure

that appellate courts do not become advocates by speculating on facts and on arguments that have not been made.” Hiner v. Hiner, 573 S.W.3d 732, 734 (Mo. App. W.D. 2019) (citation and internal quotation marks omitted). “An appellant’s

failure to substantially comply with Rule 84.04 preserves nothing for our review

and constitutes grounds for dismissal of the appeal.” Id. (citation and internal

quotation marks omitted). Even though Holding appears pro se, she “is subject to

the same procedural rules as parties represented by counsel, including rules

specifying the required contents of appellate briefs.” Hoover v. Hoover, No.

WD81697, 2019 WL 1904915, at *1 (Mo. App. W.D. April 30, 2019) (citation and

internal quotation marks omitted).

Holding’s brief fails to comply with Rule 84.04 in multiple significant

respects. First, her statement of facts does not comply with Rule 84.04(c). “Rule

84.04(c) requires appellants to include ‘a fair and concise statement of the facts

relevant to the questions presented for determination without argument.’” Interest

of D.A.B., 570 S.W.3d 606, 613 (Mo. App. E.D. 2019) (citation omitted). “The

primary purpose of the statement of facts is to afford an immediate, accurate,

complete and unbiased understanding of the facts of the case.” Hiner, 573 S.W.3d

at 735 (citation and internal quotation marks omitted). Additionally, “all

statements of facts shall have specific page references to the relevant portion of the

record on appeal, i.e., legal file, transcript, or exhibits.” Id. (citation and internal quotation marks omitted).

Holding’s eight-page statement of facts is not a fair and concise statement of

the facts relevant to the questions presented. Instead, it is one-sided and

argumentative, and the majority of Holding’s factual assertions are not supported

by citations to the record. Upon review of the few record citations which do appear

in Holding’s factual statement, they do not support the factual assertions to which

they are attached. Moreover, Holding’s factual statement does not clearly explain

the procedural history of the case; indeed, from her factual statement, it is unclear whether the circuit court ruled against her on summary judgment, or following a

2 jury trial. “It is not the role of an appellate court to serve as an advocate for a

litigant, and ‘we have no duty to search the transcript or record to discover the facts

which substantiate a point on appeal. That is the duty of the parties, not the

function of an appellate court.’” Midtown Home Improvements, Inc. v. Taylor, No.

ED106721, 2019 WL 1029609, at *2 (Mo. App. E.D. March 5, 2019) (citation

omitted).

Second, Holding’s Point Relied On is deficient.

Where, as here, an appellate court is asked to review the decision of a trial court, “each point shall (A) [i]dentify the trial court ruling or action that the appellant challenges; (B) [s]tate concisely the legal reasons for the appellant’s claim of reversible error; and (C) [e]xplain in summary fashion why, in the context of the case, those legal reasons support the claim of reversible error.” Rule 84.04(d)(1). “The point shall be in substantially the following form: ‘The trial court erred in [identify the challenged ruling or action], because [state the legal reasons for the claim of reversible error], in that [explain why the legal reasons, in the context of the case, support the claim of reversible error].’” Hiner, 573 S.W.3d at 735 (citation omitted; alterations and emphasis in original).

Holding’s Point Relied On fails to comply with Rule 84.04(d).1 Besides the

fact that Holding’s Point Relied On contains at least four distinct claims of error,

and is thus multifarious, it is not substantially in the form required by Rule 84.04(d)(1). The point does not “[s]tate concisely the legal reasons for the . . . claim

of reversible error” or “[e]xplain . . . why, in the context of the case, those legal

reasons support the claim or reversible error.” Rule 84.04(d)(1). The deficiencies in

1 Holding’s point relied on contends that: THE CIRCUIT COURT ERRED LACKING ALL INFORMATION OF THE PLAINTIFF’S CASE INVOLVING ALL THE FACTS PLAINTIFF STATES IN INTERROGATORIES AND DEPOSITION. THE CIRCUIT COURT ERRED IN PRESENTING PLAINTIFF’S CERTAIN EVIDENCE TO CIRCUIT COURT AND JURY. AND THAT THE CIRCUIT COURT DID NOT LET THE PLAINTIFF PRESENT IMPORTANT EVIDENCE FACTS, CONCERNING THE CLAIM FORM FOR INJURY OF LOSS. AND DEFENDANT AND CIRCUIT COURT DID NOT CONSIDER THE “SUDDEN ONSET” DOCTRINE OR CAUSAL CONNECTION.

3 Holding’s Point Relied On are compounded by the fact that she included at least

eight different, additional claims of error in the Point Relied On reproduced in her

brief’s Table of Contents, and in the Standard of Review section of her brief. During

oral argument, Holding identified additional alleged errors beyond those mentioned

in her brief.

“The purpose of the points relied on is to give notice to the opposing party of

the precise matters which must be contended with and to inform the court of the

issues presented for review.” Hiner, 573 S.W.3d at 735–36 (citation and internal

quotation marks omitted).

Deficient points relied on force the appellate court to search the argument portion of the brief or the record itself to determine and clarify the appellant's assertions, thereby wasting judicial resources, and, worse yet, creating the danger that the appellate court will interpret the appellant’s contention differently than the appellant intended or his opponent understood. Callahan v. Precythe, No. WD81964, 2019 WL 2504155, at *2 (Mo. App. W.D. June

18, 2019) (citation omitted). Because it is unclear from Holding’s Point Relied On

what rulings of the circuit court she intends to challenge on appeal, and on what

basis she contends those rulings were erroneous, her Point Relied On is plainly

deficient. Finally, Holding’s argument fails to comply with Rule 84.04(e). “Under Rule

84.04(e), a brief must include an argument section that discusses the points relied

on.” Hiner, 573 S.W.3d at 736 (citation omitted). “To develop a point relied on, the

argument should show how the principles of law and the facts of the case interact.”

Id. (citation and internal quotation marks omitted). Holding’s brief does not contain

Free access — add to your briefcase to read the full text and ask questions with AI

Related

In the Interest of: D.A.B. and B.M.S.
570 S.W.3d 606 (Missouri Court of Appeals, 2019)
Carla K. Hiner v. John W. Hiner
573 S.W.3d 732 (Missouri Court of Appeals, 2019)
Independent Taxi Drivers Ass'n v. Metropolitan Taxicab Commission
524 S.W.3d 157 (Missouri Court of Appeals, 2017)
Main v. Fariss
561 S.W.3d 104 (Missouri Court of Appeals, 2018)
State v. Hinton
561 S.W.3d 433 (Missouri Court of Appeals, 2018)
Bartsch v. BMC Farms, LLC
573 S.W.3d 737 (Missouri Court of Appeals, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
Linda A. Holding v. Kansas City Area Transportation Authority, Counsel Stack Legal Research, https://law.counselstack.com/opinion/linda-a-holding-v-kansas-city-area-transportation-authority-moctapp-2019.