Missouri Supreme Court
JEFFERSON CITY — The Supreme Court of Missouri has upheld a lower court’s ruling in favor of St. Louis in a Sunshine Law dispute brought by a resident, concluding he failed to meet the demanding standard required to overturn the judgment as against the weight of the evidence.
The decision affirms a finding by St. Louis Circuit Court that the city did not violate Missouri’s open-records law when it declined to produce traffic stop data in the specific format Phillip Week requested.
Weeks appealed after the circuit court ruled against him on his petition seeking to compel the city to release records under Missouri’s Sunshine Law, the Nov. 4 court opinion states.
Weeks had asked the St. Louis Metropolitan Police Department for the databases containing traffic stop data for the years 2014 through 2018, including officer PINs or DSNs collected under the law.
The Department maintained this data in computerized .CSV files.
In his request, Weeks stated he was seeking the databases in “worksheet, ie excel workbook formatting,” and later clarified via email that he wanted the data “in spreadsheet formatting (preferably in excel)” and not the underlying vehicle stop forms.
The Department responded that it could not determine what Weeks meant by “vehicle stop forms,” but offered instead to provide more than 150,000 traffic analysis reports with redacted DSNs for $1,040.
Weeks declined that option and filed suit, alleging the city knowingly and purposefully violated the Sunshine Law by refusing to produce responsive records.
During discovery, the city produced .CSV files of the traffic stop data.
Weeks testified that these files were “exactly” in the format he initially requested.
However, he also testified that he had specifically sought the production of the data in Excel spreadsheet format and that he “wanted it in spreadsheet formatting.”
The Department’s former systems development manager testified that no spreadsheet version of the data existed and that the Department did not maintain its traffic stop data in Excel format.
Testimony also showed conflicting views on whether the .CSV data could be accurately converted into a spreadsheet.
The circuit court ruled in the city’s favor, finding the city did “not hold or maintain an existing record responsive to [Weeks’] specific request,” because no spreadsheet-formatted database existed.
Weeks appealed, asserting the judgment was against the weight of the evidence.
Under Missouri law, a challenge to a judgment as against the weight of the evidence requires the appellant to follow a rigorous four-part analytical framework.
The Supreme Court noted that Weeks identified the disputed factual finding, the city’s lack of a spreadsheet-formatted record, but failed to complete the remaining required steps.
He did not identify all evidence supporting the circuit court’s finding, did not resolve evidentiary conflicts consistent with the circuit court’s credibility determinations and did not show that the supporting evidence lacked probative value when considered in the context of the entire record.
The court noted that the against-the-weight-of-the-evidence standard is difficult to meet and that appellate courts must give substantial deference to a trial court’s factual findings, particularly when those findings involve credibility assessments.
Weeks also argued the city made a binding admission under Rule 59.01 by acknowledging it had .CSV files in its possession at the time of his request.
But the Supreme Court disagreed with his characterization. The city admitted only that it had not produced .CSV files in response to the request, not that the files were responsive to the request as Weeks described it.
The circuit court made consistent findings, concluding the city did possess traffic stop data but did not maintain it in the spreadsheet form Weeks specifically sought.
Because Weeks did not apply the required analytical framework and did not establish that the circuit court could not have reasonably found the facts necessary to support its judgment, the Supreme Court affirmed the ruling.
Missouri Supreme Court case number: SC101018
