breach of fiduciary duty claim (Missouri) · Go Syfert
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breach of fiduciary duty claim in Missouri

13 Missouri opinions name it 2 courts 1990–2024 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 (7)

CaseFollowedCited
Western Blue Print Co. v. Robertsgreen
mo · 2012 · cited in 3 Missouri opinions naming this issue, 2012–2023
2 sentences

2023III, LLC v. GS Hosp., LLC, 648 S.W.3d 878 , 889 (Mo. App. S.D. 2022) (affirming a grant of summary judgment on a breach of fiduciary duty claim where appellant did not challenge the trial court’s finding that a foreclosure sale did not violate any fiduciary duty). 2 Ms. Wood posits the Supreme Court of Missouri held “whether or not there has been a breach of the fiduciary duty is a question of fact, to be determined by a trier of fact” in Robinson v. Langenbach, 599 S.W.3d 167 (Mo. banc 2020); Sun Aviation, Inc. v. L-3 Commc’ns Avionics Sys., Inc., 533 S.W.3d 720 (Mo. banc 2017); and Western B

2023See Robinson, 599 S.W.3d at 179 (affirming the denial of a motion for judgment notwithstanding the verdict for a breach of fiduciary duty claim); see also Sun Aviation, 533 S.W.3d at 726-27 (finding an appellant had no duty to disclose its parent’s consolidation plans); Roberts, 367 S.W.3d at 18 (overruling a denial of a judgment notwithstanding the verdict where there was no fiduciary duty). 5 So long as a party establishes it is entitled to summary judgment as a matter of law, its fiduciary duty is no impediment.

33
Scott v. Flynngreen
moctapp · 1997 · cited in 2 Missouri opinions naming this issue, 2009–2024
2 sentences

2024See, e.g., Meyer v. Carson & Coil, 614 S.W.3d 618 , 626-27 (Mo. App. W.D. 2020) (beneficiaries of a will lacked “standing” to assert claim for legal malpractice against the attorney who drafted the will, since they were not in an attorney- client relationship with the defendant-attorney); Scott v. Flynn, 946 S.W.2d 248, 253 (Mo. App. E.D. 1997) (heirs lacked “standing” to assert a breach of fiduciary duty claim against a deceased ward’s conservator).

2009Id.

12
Dibrill ex rel. Wheeler v. Normandy Associates, Inc.green
moctapp · 2012 · cited in 1 Missouri opinions naming this issue, 2023–2023
1 sentence

2023See Smith, 644 S.W.3d at 10; see also Dibrill, 383 S.W.3d at 86 .

11
Sun Aviation, Inc. v. L-3 Communications Avionics Systems, Inc.green
mo · 2017 · cited in 1 Missouri opinions naming this issue, 2023–2023
2 sentences

2023III, LLC v. GS Hosp., LLC, 648 S.W.3d 878 , 889 (Mo. App. S.D. 2022) (affirming a grant of summary judgment on a breach of fiduciary duty claim where appellant did not challenge the trial court’s finding that a foreclosure sale did not violate any fiduciary duty). 2 Ms. Wood posits the Supreme Court of Missouri held “whether or not there has been a breach of the fiduciary duty is a question of fact, to be determined by a trier of fact” in Robinson v. Langenbach, 599 S.W.3d 167 (Mo. banc 2020); Sun Aviation, Inc. v. L-3 Commc’ns Avionics Sys., Inc., 533 S.W.3d 720 (Mo. banc 2017); and Western B

2023See Robinson, 599 S.W.3d at 179 (affirming the denial of a motion for judgment notwithstanding the verdict for a breach of fiduciary duty claim); see also Sun Aviation, 533 S.W.3d at 726-27 (finding an appellant had no duty to disclose its parent’s consolidation plans); Roberts, 367 S.W.3d at 18 (overruling a denial of a judgment notwithstanding the verdict where there was no fiduciary duty). 5 So long as a party establishes it is entitled to summary judgment as a matter of law, its fiduciary duty is no impediment.

11
Joan L. Robinson v. John F. Lagenbachgreen
moctapp · 2014 · cited in 1 Missouri opinions naming this issue, 2023–2023
1 sentence

2023See Robinson v. Lagenbach, 439 S.W.3d 853, 859 (Mo. App. E.D. 2014) (“Because [appellant] has alleged no action that breaches [respondent’s] fiduciary duty as a trustee of the voting trust, we affirm the judgment[.]”).

11
Klemme v. Bestgreen
mo · 1997 · cited in 1 Missouri opinions naming this issue, 2005–2005
1 sentence

2005See Klemme v. Best, 941 S.W.2d 493, 497 (Mo. banc 1997) (citing section 516.120(4) RSMo 1986).

11
Bockover v. Stemmermangreen
moctapp · 1986 · cited in 1 Missouri opinions naming this issue, 1996–1996
1 sentence

1996See Bockover v. Stemmerman, 708 S.W.2d 179,182 (Mo.App.1986).

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 (7)

CaseCitedYears
Jeffrey Henry v. Farmers Insurance Company, Inc. green
moctapp · 2014
2 sentences

2023“Because breach of a fiduciary duty is constructive fraud, it is an ‘action sounding in fraud or deceit.’” Id. 13 “Pecuniary damage is, therefore, an intrinsic element of a breach of fiduciary duty claim and is essential to recovery.” Id.

2023“Because breach of a fiduciary duty is constructive fraud, it is an ‘action sounding in fraud or deceit.’” Id. 13 “Pecuniary damage is, therefore, an intrinsic element of a breach of fiduciary duty claim and is essential to recovery.” Id.

12023–2023
Ramacciotti v. Joe Simpkins, Inc. green
mo · 1968
1 sentence

2000Plaintiff relies on language contained in Ramacciotti v. Joe Simpkins, Inc., 427 S.W.2d 425 (Mo.1968).

12000–2000
Jones v. Grewe green
calctapp · 1987
2 sentences

1998In affirming the trial court’s dismissal of the breach of fiduciary duty claim, the Jones court noted that insurance agents have a general duty to “use reasonable care, diligence and judgment in procuring the insurance requested by the insured.” Id. at 719 .

1998The court held that “[t]he general duty of reasonable care which an insurance agent owes his client does not include the obligation to procure a policy affording the client complete liability protection_” Id. at 720 .

11998–1998
Paisley v. Lucas green
· 1940
2 sentences

1998We do not face such doubtful language in this case. [6] The Supreme Court noted that "[o]nly in such negative promises as to forbear suit or not to carry on a business or occupation is so broad an interpretation likely to be permissible." Id. (quoting 1 Williston, Contracts, Revised Edition, § 38). [7] Kemper, 284 S.W.2d at 482 ; Paisley, 143 S.W.2d at 262 ; Haith v. Model Cities Health Corp. of Kansas City, 704 S.W.2d 684 (Mo.App. 1986) [8] We identified these defendants in note 2 supra. [9] The individual defendants' appellate brief claims, in response to the breach of fiduciary duty claim,

1998We do not face such doubtful language in this case. [6] The Supreme Court noted that "[o]nly in such negative promises as to forbear suit or not to carry on a business or occupation is so broad an interpretation likely to be permissible." Id. (quoting 1 Williston, Contracts, Revised Edition, § 38). [7] Kemper, 284 S.W.2d at 482 ; Paisley, 143 S.W.2d at 262 ; Haith v. Model Cities Health Corp. of Kansas City, 704 S.W.2d 684 (Mo.App. 1986) [8] We identified these defendants in note 2 supra. [9] The individual defendants' appellate brief claims, in response to the breach of fiduciary duty claim,

11998–1998
Superior Concrete Accessories, Inc. v. Kemper green
mo · 1955
1 sentence

1998We do not face such doubtful language in this case. [6] The Supreme Court noted that "[o]nly in such negative promises as to forbear suit or not to carry on a business or occupation is so broad an interpretation likely to be permissible." Id. (quoting 1 Williston, Contracts, Revised Edition, § 38). [7] Kemper, 284 S.W.2d at 482 ; Paisley, 143 S.W.2d at 262 ; Haith v. Model Cities Health Corp. of Kansas City, 704 S.W.2d 684 (Mo.App. 1986) [8] We identified these defendants in note 2 supra. [9] The individual defendants' appellate brief claims, in response to the breach of fiduciary duty claim,

11998–1998
Haith v. Model Cities Health Corp. green
moctapp · 1986
1 sentence

1998We do not face such doubtful language in this case. [6] The Supreme Court noted that "[o]nly in such negative promises as to forbear suit or not to carry on a business or occupation is so broad an interpretation likely to be permissible." Id. (quoting 1 Williston, Contracts, Revised Edition, § 38). [7] Kemper, 284 S.W.2d at 482 ; Paisley, 143 S.W.2d at 262 ; Haith v. Model Cities Health Corp. of Kansas City, 704 S.W.2d 684 (Mo.App. 1986) [8] We identified these defendants in note 2 supra. [9] The individual defendants' appellate brief claims, in response to the breach of fiduciary duty claim,

11998–1998
Forinash v. Daugherty green
moctapp · 1985
1 sentence

1990Forinash’s analysis is not particularly instructive for our purposes; the majority seems to think that the breach of fiduciary duty exception “carries the rule fur-ther_” Id. at 307 .

11990–1990

Where else courts name it

TX 277 (1999–2026) NY 167 (1998–2026) CA 89 (1990–2026) DE 75 (1996–2026) IL 67 (1991–2025) OH 45 (1999–2026) NC 40 (1989–2026) GA 25 (1989–2026) PA 25 (1986–2024) WA 22 (2000–2026) CO 21 (1987–2026) FL 16 (1984–2026) UT 15 (2010–2025) MA 13 (1996–2026) SC 13 (2004–2025) MO 13 (1990–2024) MD 12 (1991–2022) MI 11 (2002–2025) AL 11 (1987–2018) WI 11 (2005–2025) ME 11 (2002–2023) LA 10 (1988–2022) KY 10 (2013–2025) NJ 9 (2002–2026) IN 9 (2001–2025) VA 9 (1996–2026) AZ 8 (1999–2023) IA 8 (2000–2023) CT 8 (1998–2025) DC 8 (1992–2025) OR 8 (1979–2015) MN 7 (1999–2024) MS 6 (2001–2009) ID 6 (1992–2026) NM 5 (1997–2018) WV 5 (2018–2023) KS 5 (1992–2026) ND 4 (2004–2010) RI 4 (2003–2019) OK 3 (2009–2017) SD 2 (2009–2014) AK 2 (2010–2019) NV 2 (2010–2024) HI 2 (2025–2025)

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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