LT Group USA, LLC v. Mounanet Clark

CourtMissouri Court of Appeals
DecidedMay 2, 2023
DocketED110910
StatusPublished

This text of LT Group USA, LLC v. Mounanet Clark (LT Group USA, LLC v. Mounanet Clark) 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
LT Group USA, LLC v. Mounanet Clark, (Mo. Ct. App. 2023).

Opinion

In the Missouri Court of Appeals Eastern District DIVISION THREE

LT GROUP USA, LLC, ) No. ED110910 ) Respondent, ) Appeal from the Circuit Court ) of St. Louis County v. ) Cause No. 22SL-AC13458 ) MOUNANET CLARK, ) Honorable Jeffrey P. Medler ) Appellant. ) Filed: May 2, 2023

Introduction

Respondent LT Group USA, LLC filed an unlawful detainer action against Appellant

Mounanet Clark. The trial court entered judgment in favor of Respondent. In three points on

appeal, Appellant argues we should reverse the trial court’s judgment. We dismiss the appeal.

Procedural Background

On June 21, 2022, Respondent filed an affidavit and complaint in unlawful detainer

against Appellant. On July 5, 2022, Appellant, pursuant to Rule 55.27(a), filed a motion to

dismiss Respondent’s affidavit and complaint or, in the alternative, stay the affidavit and

complaint. Nothing in the record indicates the trial court acted on Appellant’s motion to dismiss.

Instead, on August 2, 2022, the parties appeared for trial. Evidence was adduced, and the

case was heard and submitted. Based on the pleadings, trial evidence, and credibility of the witnesses, the trial court entered judgment against Appellant for unlawful detainer of property

lawfully possessed by Respondent.

Appellant, acting pro se, appeals.

Discussion

We dismiss this appeal for a multitude of serious briefing deficiencies. See Rule 84.13(a)

(“[A]llegations of error . . . not properly briefed shall not be considered in any civil appeal . . .

.”). 1

Rule 84.04 plainly sets forth the required contents of briefs filed in all appellate courts.

Lexow v. Boeing Co., 643 S.W.3d 501, 505 (Mo. banc 2022). Rule 84.04’s requirements are

mandatory, even for pro se appellants. Id.; Mecey v. Harps Food Stores, Inc., 661 S.W.3d 14, 16

(Mo. App. E.D. 2023). Although this Court prefers to excuse technical deficiencies in a brief if

we can understand the issues and reach the merits of the case, it will not consider a brief so

deficient that it fails to give notice to this Court and to the other parties of the issue presented on

appeal. Lexow, 643 S.W.3d at 505.

This Court’s preference for reaching the merits of a case must be balanced with the

implications of doing so when presented with a deficient brief: the Court faces the dilemma of

either deciding the case and possibly setting precedent upon inadequate briefing and advocacy,

or undertaking additional research and briefing to ameliorate the deficiency in favor of one party,

to the detriment of the opposing party and of parties to other cases awaiting disposition. See id.

(citing Thummel v. King, 570 S.W.2d 679, 686 (Mo. banc 1978)). Merely reiterating the

importance of our mandatory briefing rules without consequence “implicitly condones continued

1 All rule references are to the Missouri Supreme Court Rules (2022) unless otherwise indicated.

2 violations and undermines the mandatory nature of the rules.” Young v. Missouri Dep’t of Soc.

Servs., 647 S.W.3d 73, 76 (Mo. App. E.D. 2022).

Rule 84.04(c): Statement of Facts

An appellant’s brief must contain “a fair and concise statement of the facts relevant to the

questions presented for determination without argument.” Rule 84.04(c). Appellant’s statement

of facts is riddled with arguments and asides irrelevant to the questions presented.

A statement of facts must also “have specific page references to the relevant portion of

the record on appeal.” Id. “If the portion cited is contained in the appendix, a page reference to

the appendix shall also be included.” Id. Many of the factual allegations and arguments contained

in Appellant’s statement of facts have no page references to the record on appeal or the

appendix. 2 Though some paragraphs in the statement of facts are followed by references to the

legal file, these sporadic references are insufficient under Rule 84.04(c). Lexow, 643 S.W.3d at

508. For every statement of fact, a specific page reference is required. Id.

Rule 84.04(d): Points Relied On

Points relied on are central to the formation of a brief. Lexow, 643 S.W.3d at 505.

Appellants points relied on are lacking in multiple respects.

First, a point relied on which does not state “wherein and why” the trial court erred does

not comply with Rule 84.04(d) and preserves nothing for appellate review. Id.; Rule 84.04(d)(1).

In compliance with Rule 84.04(d)(1)(A), Appellant’s points do appear to “[i]dentify the trial

court ruling or action” that she challenges, thus accounting for the “wherein” requirement. See

Lexow, 643 S.W.3d at 505. But Appellant’s points fail to address “why” the trial court’s alleged

errors merit reversal. See id.; see also Rule 84.04(d)(1)(B)-(C). This is of particular concern

2 Appellant’s legal file also is deficient in that the pages of volume two are not consecutively numbered. See Rule 81.12(b)(2)(E).

3 given that Rule 84.04(d) “itself provides a simple template for an appellant to follow to ensure

compliance with the rule.” 3 Lexow, 643 S.W.3d at 505. Considering that a template is

specifically provided in Rule 84.04(d)(1), appellants simply have no excuse for failing to submit

adequate points relied on. Young, 647 S.W.3d 77. Here, “each point relied on wholly fails to

follow the simple template provided in Rule 84.04(d). The points are not substantially in the

form provided by the rule, as required.” Lexow, 643 S.W.3d at 507.

Second, in a point relied on, “[a]ny reference to the record shall be limited to the ultimate

facts necessary to inform the appellate court and the other parties of the issues. Detailed

evidentiary facts shall not be included.” Rule 84.04(d)(4). Appellant’s third point blatantly

violates this rule. 4

Third, “[i]mmediately following each ‘Point Relied On,’ the appellant . . . shall include a

list of cases, not to exceed four, and the . . . statutory, and . . . other authority upon which that

party principally relies.” Rule 84.04(d)(5). Immediately following Appellant’s first, second, and

third points are lists containing eight, 18, and ten cases, respectively, all vastly exceeding the

four-case maximum.

Rule 84.04(e): Argument

3 “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].’” Rule 84.04(d)(1). 4 Appellant’s third point relied on states in full: The trial court erred in finding that Respondent’s title was superior to Appellant’s when Appellant’s claims at trial, inter alia, were that her title was superior to Respondent’s in that Appellant acquired a fee simple ownership interest in the property based on her purchase of the property from a Missouri trust owned and controlled by Gregory Dixson, a convicted felon serving time for drug trafficking, wherein Gregory Dixson took a $50,000.00 deposit from Appellant based on a lawful contract, where thereunder Gregory Dixson executed a Quitclaim Deed in favor of Appellant, and then immediately thereafter, Gregory Dixson pledged the same subject property as collateral for a loan on which Gregory Dixson defaulted, giving rise [sic] the foreclosure upon which Respondent’s claim of ownership is based, where the loan that Gregory Dixson obtained was procured by fraud.

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Related

Murphy v. Carron
536 S.W.2d 30 (Supreme Court of Missouri, 1976)
Thummel v. King
570 S.W.2d 679 (Supreme Court of Missouri, 1978)
Sullivan v. Holbrook
109 S.W. 668 (Supreme Court of Missouri, 1908)

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LT Group USA, LLC v. Mounanet Clark, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lt-group-usa-llc-v-mounanet-clark-moctapp-2023.