KANSAS CITY — The Missouri Court of Appeals for the Western District has dismissed an appeal filed by Kansas City activist and former mayoral candidate Clay Chastain, citing his failure to comply with appellate briefing requirements.
The October 21 decision, issued by Judge W. Douglas Thomson with all judges concurring, upheld a lower court’s summary judgment in favor of the city of Kansas City, Mayor Quinton Lucas and City Manager Brian Platt.
Chastain, who represented himself in the appeal, challenged the Jackson Circuit Court’s ruling that granted summary judgment to the city.
The appellate court, however, did not consider the merits of his arguments because his filing violated nearly every provision of Rule 84.04 of the Missouri Rules of Civil Procedure, which governs the format and content of appellate briefs, the decision stated.
The court noted that Chastain has “extensive experience” with the appellate system, citing multiple past cases involving him dating back more than two decades.
The dispute at the center of the case stemmed from an incident at City Hall in February 2023, during the Kansas City mayoral campaign.
Chastain, who ran against Lucas, the incumbent mayor, attended a public City Council hearing with the intention of asking Lucas why he refused to debate him.
According to the court document, security warned Chastain that campaigning inside City Hall was not permitted and asked him to leave.
When he refused, he was arrested for trespassing. Chastain was later acquitted of the criminal charges.
Following his arrest, Chastain filed a federal lawsuit in the U.S. District Court for the Western District of Missouri against the city and Lucas, alleging violations of his First and Fourth Amendment rights.
The defendants moved to dismiss the complaint for failure to state a claim. The federal court granted that motion, and the Eighth Circuit Court of Appeals later affirmed the decision.
Chastain then filed a new lawsuit in Jackson Circuit Court, naming the city, Lucas and Platt as defendants. His claims included malicious arrest, malicious prosecution and election interference.
The city sought dismissal of the case, arguing that Chastain failed to state a claim upon which relief could be granted. The trial court agreed in part, dismissing the election interference claim but allowing the claims of malicious prosecution and false imprisonment to proceed.
The city later filed a motion for summary judgment, which the trial court granted, leading to Chastain’s appeal.
The appellate court noted that it occasionally reviews non-compliant briefs from self-represented litigants “ex gratia” when the appellant’s arguments can still be understood despite minor deficiencies. In Chastain’s case, however, the court concluded that his violations were too extensive to overlook.
“Chastain’s violations of Rule 84.04 are not minor,” Thomson wrote, explaining that addressing his appeal would require the judges to “comb the record for support for his factual assertions, decipher his points on appeal, and locate legal authority for his arguments.”
Doing so, the court said, would effectively make the judges advocates on Chastain’s behalf.
While the court acknowledged that dismissing a case without addressing its merits can feel unjust to litigants, it found that Chastain’s noncompliance left no other option.
“A party’s sense of justice is not met when their case is not decided upon the merits,” the opinion stated, quoting prior precedent. “However, addressing the merits of Chastain’s appeal would require us to become Chastain’s advocates. This, we cannot do.”
Because Chastain’s brief failed to meet the required standards, the appellate court ruled that he preserved nothing for review. The appeal was dismissed.
Missouri Court of Appeals for the Western District case number: WD87587
