finality requirement (Missouri) · Go Syfert
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finality requirement in Missouri

25 Missouri opinions name it 2 courts 1906–2025 4 in the last five years

The cases below were cited by Missouri courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (15)

CaseFollowedCited
Polk v. Essengreen
moctapp · 2008 · cited in 2 Missouri opinions naming this issue, 2009–2016
2 sentences

2016However, Rule 74.01(b) provides an exception to the finality rule, “permitting a trial court to enter judgment on a single claim when multiple claims are asserted in a single case and certify its judgment as appealable upon an express determination there is ‘no just reason for delay.’” Polk v. Essen, 249 S.W.3d 914, 918 (Mo. App. E.D. 2008); Davis v. Howe, 144 S.W.3d 899, 902 (Mo. App. E.D. 2004).

2009Rule 74.01(b), however, provides an exception to the finality rule, permitting a trial court to enter judgment on a single claim when multiple claims are asserted in a single case and certify its judgment as appealable upon an express determination there is “no just reason for delay.” Polk v. Essen, 249 S.W.3d 914, 918 (Mo.App.

22
Haley v. City of Linn Creekgreen
moctapp · 1979 · cited in 2 Missouri opinions naming this issue, 1984–1985
2 sentences

1985Greening v. Klamen, 683 S.W.2d 298, 300 (Mo.App.1984) citing, Haley v. City of Linn Creek, 583 S.W.2d 590, 591 (Mo.App.1979).

1984Haley v. City of Linn Creek, 583 S.W.2d 590, 591 (Mo.App.1979).

22
First National Bank of Dieterich v. Pointe Royale Property Owners' Ass'ngreen
mo · 2017 · cited in 5 Missouri opinions naming this issue, 2018–2025
2 sentences

2025Rule 74.01(b) “provides a limited exception to this finality requirement.” Id.

2020Rule 74.01(b) “provides a limited exception to this finality requirement.” Id.

15
Davis v. Howegreen
moctapp · 2004 · cited in 2 Missouri opinions naming this issue, 2008–2016
2 sentences

2016However, Rule 74.01(b) provides an exception to the finality rule, “permitting a trial court to enter judgment on a single claim when multiple claims are asserted in a single case and certify its judgment as appealable upon an express determination there is ‘no just reason for delay.’” Polk v. Essen, 249 S.W.3d 914, 918 (Mo. App. E.D. 2008); Davis v. Howe, 144 S.W.3d 899, 902 (Mo. App. E.D. 2004).

2008Rule 74.01(b), however, provides an exception to the finality rule, permitting a trial court to enter judgment on a single claim when multiple claims are asserted in a single case and certify its judgment as appealable upon an express determination there is “no just reason for delay.” Davis, 144 S.W.3d at 902 ; Albright, 926 S.W.2d at 209 .

12
Buemi v. Kerckhoffgreen
mo · 2011 · cited in 1 Missouri opinions naming this issue, 2025–2025
1 sentence

2025Where multiple claims are presented in an action, “[t]he rule authorizes the trial court to enter an appealable final judgment as to fewer than all claims or parties in the case and to certify that there is no just reason to delay the appeal of that judgment.” Buemi v. Kerckhoff, 359 S.W.3d 16, 20 (Mo. banc 2011). “[T]he effect of Rule 74.01(b) is to permit severance of any unrelated substantive claim for relief of the parties and to allow appeal of a final judgment on those severed claims.” First Nat’l Bank of Dieterich, 515 S.W.3d at 222 (emphasis and internal quotation omitted).

11
Owens v. Division of Employment Securitygreen
moctapp · 2008 · cited in 1 Missouri opinions naming this issue, 2025–2025
1 sentence

2025See Citizens for Ground Water Prot., 275 S.W.3d at 352 .

11
In the Interest of J.I.S. v. Waldongreen
mo · 1990 · cited in 1 Missouri opinions naming this issue, 2023–2023
1 sentence

2023As this Court has observed when enforcing other limits on the right to appeal under section 211.261, the General Assembly decides when an appeal can be taken in juvenile proceedings: “The right of appeal is statutory. . . . [T]his Court cannot invade the General Assembly’s province to create a right of appeal where none exists.” J.I.S. v. Waldon, 791 S.W.2d 379, 379 (Mo. banc 1990) (internal citation omitted).

11
Committee for Educational Equality v. Stategreen
mo · 1994 · cited in 1 Missouri opinions naming this issue, 2023–2023
1 sentence

2023Equality v. State, 878 S.W.2d 446, 451 (Mo. 1994) (citation omitted).

11
Huff v. DEWEY & LEBOEUF, LLPgreen
moctapp · 2011 · cited in 1 Missouri opinions naming this issue, 2012–2012
1 sentence

2012Rule 74.01(b) permits the circuit court to designate a final judgment “as to one or more but fewer than all of the claims or parties only upon an express determination that there is no just reason for delay.” Upon entering the partial summary judgment in this case, the circuit court expressly invoked Rule 74.01(b) by stating “there is no just cause to delay entering judgment as provided herein on the portion of the action which is disposed of by this judgment.” However, the circuit court’s “certification of a judgment as final is not conclusive.” Huff v. Dewey & LeBoeuf, LLP, 340 S.W.3d 623, 6

11
Davis v. Dolgencorp, Inc.green
moctapp · 1989 · cited in 1 Missouri opinions naming this issue, 2012–2012
1 sentence

2012Rule 74.01(b) 5 provides an exception to the finality rule in cases “in which more than one claim for relief is presented or when multiple parties are involved.” Davis v. Dolgencorp, Inc., 774 S.W.2d 565, 567 (Mo.App.1989).

11
Doerr v. Teton Transportation, Inc.green
moctapp · 2008 · cited in 1 Missouri opinions naming this issue, 2010–2010
1 sentence

2010See, e.g., Doerr, 258 S.W.3d at 520-21 ; Braswell, 249 S.W.3d at 297-98 .

11
Cramer v. Smootgreen
moctapp · 2009 · cited in 1 Missouri opinions naming this issue, 2010–2010
1 sentence

2010Cramer v. Smoot, 291 S.W.3d 337, 339 (Mo.App.2009); see section 512.020(5). 4 Rule 74.01(b) provides an exception to this finality rule for cases with multiple claims.

11
Masonic Temple Ass'n v. Compass Square and Star, Inc.green
moctapp · 2007 · cited in 1 Missouri opinions naming this issue, 2008–2008
1 sentence

2008The purpose of this rule is “to avoid *919 redundant review of multiple appeals based on the same underlying facts and similar legal issues.” Masonic Temple Ass’n v. Compass Square and Star, Inc., 229 S.W.3d 134, 137 (Mo.App.

11
Morris v. Pattersongreen
moctapp · 1977 · cited in 1 Missouri opinions naming this issue, 1999–1999
1 sentence

1999Morris v. Patterson, 549 S.W.2d 613, 614 (Mo.App.1977). *109 While Rule 74.01(b) permits the trial court to decide fewer than all claims, it does not dispense with the finality requirement for the claims adjudged.

11
Greening v. Klamengreen
moctapp · 1984 · cited in 1 Missouri opinions naming this issue, 1985–1985
1 sentence

1985Greening v. Klamen, 683 S.W.2d 298, 300 (Mo.App.1984) citing, Haley v. City of Linn Creek, 583 S.W.2d 590, 591 (Mo.App.1979).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Missouri. Read the followed side critically anyway.

Also cited on this issue (21)

CaseCitedYears
Gibson v. Brewer green
mo · 1997
2 sentences

2019Gibson, 952 S.W.2d at 244 ; Crawford, 561 S.W.3d at 466 .

2002Gibson, 952 S.W.2d at 244 ; In re Marriage of Werths, 33 S.W.3d 541 , 542 n. 1 (Mo. banc 2000).

31999–2019
Crawford v. Distrib. Operations, Inc. green
moctapp · 2018
1 sentence

2019Gibson, 952 S.W.2d at 244 ; Crawford, 561 S.W.3d at 466 .

12019–2019
White v. Anderssen Mobile X-Ray Service green
moctapp · 2012
1 sentence

2018"The 2005 amendments altered neither the Commission's authority to enter temporary or partial awards pursuant to section 287.510 nor appellate jurisdiction pursuant to section 287.495." White v. Anderssen Mobile X-Ray Serv. , 389 S.W.3d 222 , 224 (Mo. App. E.D. 2012).

12018–2018
West v. Sharp Bonding Agency, Inc. green
moctapp · 2010
1 sentence

2012Rule 74.01(b) permits the circuit court to designate a final judgment “as to one or more but fewer than all of the claims or parties only upon an express determination that there is no just reason for delay.” Upon entering the partial summary judgment in this case, the circuit court expressly invoked Rule 74.01(b) by stating “there is no just cause to delay entering judgment as provided herein on the portion of the action which is disposed of by this judgment.” However, the circuit court’s “certification of a judgment as final is not conclusive.” Huff v. Dewey & LeBoeuf, LLP, 340 S.W.3d 623, 6

12012–2012
Braswell v. Missouri State Highway Patrol green
moctapp · 2008
1 sentence

2010See, e.g., Doerr, 258 S.W.3d at 520-21 ; Braswell, 249 S.W.3d at 297-98 .

12010–2010
Albright v. Kelley green
moctapp · 1996
1 sentence

2008Rule 74.01(b), however, provides an exception to the finality rule, permitting a trial court to enter judgment on a single claim when multiple claims are asserted in a single case and certify its judgment as appealable upon an express determination there is “no just reason for delay.” Davis, 144 S.W.3d at 902 ; Albright, 926 S.W.2d at 209 .

12008–2008
Nooney v. Nationsbank, N.A. green
moctapp · 1999
1 sentence

2003Id.

12003–2003
In Re the Marriage of Werths green
mo · 2000
1 sentence

2002Gibson, 952 S.W.2d at 244 ; In re Marriage of Werths, 33 S.W.3d 541 , 542 n. 1 (Mo. banc 2000).

12002–2002
Spectrum Cleaning Services Inc. v. Blalack green
moctapp · 1999
1 sentence

2001However, “Rule 74.01(b) provides an exception to the finality rule for cases involving multiple claims, allowing the trial court to enter judgment on less than all claims and certify that there is no just reason for delay.” Id.

12001–2001
International Minerals & Chemical Corp. v. Avon Products, Inc. green
mo · 1991
2 sentences

1994This Court concluded that there was ample authority “for defining by rule the scope of the finality requirement so as to include a determination that could be made subject of a separate judgment.” 817 S.W.2d at 906 .

1994This Court concluded that there was ample authority "for defining by rule the scope of the finality requirement so as to include a determination that could be made subject of a separate judgment." 817 S.W.2d at 906 .

11994–1994
Barber Asphalt Paving Co. v. Field neutral
moctapp · 1906
2 sentences

1911We believe the correct rule to be used in measuring the effect of a former adjudication is stated by the Kansas City Court of Appeals in Paving Company v. Field, 132 Mo. App. 628 , 97 S. W. 179 , as follows: “Where the two actions present the same parties, the same subject- matter and the same claim or demand, a judgment in the first action, if rendered on the merits, constitutes an absolute bar to the second action. ‘It is a finality as to the claim or demand in controversy concluding parties and those in privity with them, not only as to every matter which was offered and received to sustain

1911We believe the correct rule to be used in measuring the effect of a former adjudication is stated by the Kansas City Court of Appeals in Paving Company v. Field, 132 Mo. App. 628 , 97 S. W. 179 , as follows: “Where the two actions present the same parties, the same subject- matter and the same claim or demand, a judgment in the first action, if rendered on the merits, constitutes an absolute bar to the second action. ‘It is a finality as to the claim or demand in controversy concluding parties and those in privity with them, not only as to every matter which was offered and received to sustain

11911–1911
Cromwell v. County of Sac green
scotus · 1877
1 sentence

1906“It is a finality as to the claim or demand in controversy concluding parties and those in privity with them, not only as to every matter which was offered and received to sustain or defeat the claim or demand but as to any other admissible matter which might have been offered for that purpose.” [Cromwell v. County of Sac, 94 U. S. 351 ; Dickey v. Heim, 48 Mo. App. 114 ; Barkhoefer v. Barkhoefer, 93 Mo. App. 373 ; Viertel v. Viertel, 99 Mo. App. 710 ; Ruckman v. Union Railway, 45 Ore. 578 ; Empire State Nail Co. v. American, etc., Co., 74 Fed. 864 ; Mining Co. v. Mining Co., 157 U. S. 683 ; Pe

11906–1906
Last Chance Mining Co. v. Tyler Mining Co. green
· 1895
11906–1906
Barkhoefer v. Barkhoefer neutral
· 1902
1 sentence

1906“It is a finality as to the claim or demand in controversy concluding parties and those in privity with them, not only as to every matter which was offered and received to sustain or defeat the claim or demand but as to any other admissible matter which might have been offered for that purpose.” [Cromwell v. County of Sac, 94 U. S. 351 ; Dickey v. Heim, 48 Mo. App. 114 ; Barkhoefer v. Barkhoefer, 93 Mo. App. 373 ; Viertel v. Viertel, 99 Mo. App. 710 ; Ruckman v. Union Railway, 45 Ore. 578 ; Empire State Nail Co. v. American, etc., Co., 74 Fed. 864 ; Mining Co. v. Mining Co., 157 U. S. 683 ; Pe

11906–1906
Dickey v. Heim neutral
moctapp · 1892
1 sentence

1906“It is a finality as to the claim or demand in controversy concluding parties and those in privity with them, not only as to every matter which was offered and received to sustain or defeat the claim or demand but as to any other admissible matter which might have been offered for that purpose.” [Cromwell v. County of Sac, 94 U. S. 351 ; Dickey v. Heim, 48 Mo. App. 114 ; Barkhoefer v. Barkhoefer, 93 Mo. App. 373 ; Viertel v. Viertel, 99 Mo. App. 710 ; Ruckman v. Union Railway, 45 Ore. 578 ; Empire State Nail Co. v. American, etc., Co., 74 Fed. 864 ; Mining Co. v. Mining Co., 157 U. S. 683 ; Pe

11906–1906
Viertel v. Viertel neutral
moctapp · 1903
11906–1906
Empire State Nail Co. v. American Solid Leather Button Co. neutral
ca1 · 1896
11906–1906
Ruckman v. Union Railway Co. green
or · 1904
11906–1906
Des Moines & Fort Dodge Railway Co. v. Bullard neutral
iowa · 1893
11906–1906
Lindemann v. Rusk green
· 1905
11906–1906
Sayers v. Auditor General neutral
mich · 1900
1 sentence

1906“It is a finality as to the claim or demand in controversy concluding parties and those in privity with them, not only as to every matter which was offered and received to sustain or defeat the claim or demand but as to any other admissible matter which might have been offered for that purpose.” [Cromwell v. County of Sac, 94 U. S. 351 ; Dickey v. Heim, 48 Mo. App. 114 ; Barkhoefer v. Barkhoefer, 93 Mo. App. 373 ; Viertel v. Viertel, 99 Mo. App. 710 ; Ruckman v. Union Railway, 45 Ore. 578 ; Empire State Nail Co. v. American, etc., Co., 74 Fed. 864 ; Mining Co. v. Mining Co., 157 U. S. 683 ; Pe

11906–1906

Statutes the citing opinions construe

MO § Mo. Rev. Stat. § 512.020 (15) USC § 42u.s.c.1983 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 61 (1937–2023) PA 47 (1953–2026) CT 34 (1982–2025) CA 30 (1977–2025) FL 30 (1965–2020) NY 29 (1900–2024) MD 29 (1971–2022) DC 27 (1980–2026) TN 25 (1961–2026) MO 25 (1906–2025) HI 21 (1984–2022) AR 20 (1986–2025) VT 20 (1987–2026) IN 18 (1970–2024) MA 17 (1984–2025) IL 16 (1978–2023) AK 16 (1971–2023) WV 16 (1995–2024) GA 14 (1979–2024) OH 14 (1974–2025) WA 14 (1985–2018) MN 14 (1985–2017) NM 14 (1904–2023) AZ 12 (1982–2021) SD 12 (1905–2020) KY 11 (1988–2023) WI 10 (1987–2026) CO 9 (1949–2019) MI 9 (1933–2021) OR 9 (1917–2019) RI 8 (1974–2024) NJ 8 (1912–2017) ID 7 (1981–2023) IA 7 (1932–2025) NE 6 (1970–2017) OK 6 (1915–2006) UT 6 (1994–2024) VI 5 (2002–2010) KS 5 (2001–2017) ND 5 (1988–2021) NV 4 (2013–2021) WY 3 (1985–1989) MT 3 (1978–2006) AL 3 (1899–1946) VA 3 (2005–2024) DE 3 (2010–2021) MS 2 (1991–2013) LA 2 (2002–2004) SC 2 (2010–2026) MP 2 (1999–2025)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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