rigorous standard (Missouri) · Go Syfert
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rigorous standard in Missouri

13 Missouri opinions name it 2 courts 1958–2025 2 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 (11)

CaseFollowedCited
PLANNED PARENT. MN, N. DAKOTA, S. DAKOTA v. Roundsgreen
ca8 · 2008 · cited in 2 Missouri opinions naming this issue, 2025–2025
2 sentences

2025See Planned Parenthood Minn., N.D., S.D., v. Rounds, 530 F.3d 724, 731-33 (8th Cir. 2008).

2025Instead, the movant must meet the more rigorous standard of showing that they are “likely to prevail on the merits.” Id. at 732; State ex rel.

22
Turley v. Turleygreen
mo · 1999 · cited in 2 Missouri opinions naming this issue, 2001–2004
2 sentences

2004Turley v. Turley, 5 S.W.3d 162, 164 (Mo. banc 1999); Stirling v. Maxwell, 45 S.W.3d 914, 916 (Mo.App.2001).

2001Turley v. Turley, 5 S.W.3d 162, 164 (Mo. banc 1999).

22
Howard v. Pettusgreen
moctapp · 1988 · cited in 2 Missouri opinions naming this issue, 1992–1996
2 sentences

1996“In comparison to attorney prepared pleadings, a pro se petition is held to a less rigorous standard and ‘is subject to summary dismissal if it is patently and irreparably frivolous or malicious on its face so that, as pleaded, the plaintiff could prove no set of facts entitling him to relief.” Watley v. Missouri Bd. of Probation and Parole, 863 S.W.2d 337, 338 (Mo.App.1992)(quoting Howard v. Pettus, 745 S.W.2d 821, 822 (Mo.App.1988)).

1992In comparison to attorney prepared pleadings, a pro se petition is held to a less rigorous standard and “is subject to summary dismissal if it is patently and irreparably frivolous or malicious on its face so that, as pleaded, the plaintiff could prove no set of facts entitling him to relief.” Howard v. Pettus, 745 S.W.2d 821, 822 (Mo.App.1988).

22
Watley v. Missouri Board of Probation & Parolegreen
moctapp · 1992 · cited in 2 Missouri opinions naming this issue, 1996–2002
2 sentences

2002Id. “[I]n determining whether a pro se petition states a cause of action, the petition must be viewed favorably to the pleader, given the benefit of every reasonable intendment, and indulged with liberality.” Id.

1996“In comparison to attorney prepared pleadings, a pro se petition is held to a less rigorous standard and ‘is subject to summary dismissal if it is patently and irreparably frivolous or malicious on its face so that, as pleaded, the plaintiff could prove no set of facts entitling him to relief.” Watley v. Missouri Bd. of Probation and Parole, 863 S.W.2d 337, 338 (Mo.App.1992)(quoting Howard v. Pettus, 745 S.W.2d 821, 822 (Mo.App.1988)).

12
cluster 686441green
ca1 · 1995 · cited in 1 Missouri opinions naming this issue, 2025–2025
1 sentence

2025Kehoe, 2025 WL 1564397 , at *1. “[A] more rigorous standard 28 ‘reflects the idea that governmental policies implemented through legislation or regulations developed through presumptively reasoned democratic processes are entitled to a higher degree of deference and should not be enjoined lightly.’” 11 Rounds, 530 F.3d at 732 (quoting Able v. United States, 44 F.3d 128, 131 (2d Cir. 1995)).

11
White v. Stategreen
moctapp · 2006 · cited in 1 Missouri opinions naming this issue, 2006–2006
1 sentence

2006However, this court has repeatedly held that a pro se litigant “is bound by the same rules of procedure as those admitted to practice law and is entitled to no indulgence he would not have received if represented by counsel.” White v. State, 192 S.W.3d 487, 490 (Mo.App.2006).

11
Stirling v. Maxwellgreen
moctapp · 2001 · cited in 1 Missouri opinions naming this issue, 2004–2004
1 sentence

2004Turley v. Turley, 5 S.W.3d 162, 164 (Mo. banc 1999); Stirling v. Maxwell, 45 S.W.3d 914, 916 (Mo.App.2001).

11
Kennedy v. Missouri Attorney Generalgreen
moctapp · 1996 · cited in 1 Missouri opinions naming this issue, 2002–2002
2 sentences

2002Cf. Moore v. Swisher Mower & Machine Co., Inc., 49 S.W.3d 731, 736-37 (Mo.App.2001) (addressing pro se appellant’s point relied on despite technical deficiency and general rule that pro se litigants must adhere to the same procedural requirements as lawyers because court was able to ascertain the issues and the arguments); Kennedy v. Missouri Attorney General, 922 S.W.2d 68, 70 (Mo.App.1996) (stating that in comparison to attorney prepared pleadings, a pro se petition is held to a less rigorous standard).

2002Cf. Moore v. Swisher Mower & Machine Co., Inc., 49 S.W.3d 731, 736-37 (Mo.App.2001) (addressing pro se appellant’s point relied on despite technical deficiency and general rule that pro se litigants must adhere to the same procedural requirements as lawyers because court was able to ascertain the issues and the arguments); Kennedy v. Missouri Attorney General, 922 S.W.2d 68, 70 (Mo.App.1996) (stating that in comparison to attorney prepared pleadings, a pro se petition is held to a less rigorous standard).

11
Moore v. Swisher Mower & MacHine Co., Inc.green
moctapp · 2001 · cited in 1 Missouri opinions naming this issue, 2002–2002
2 sentences

2002Cf. Moore v. Swisher Mower & Machine Co., Inc., 49 S.W.3d 731, 736-37 (Mo.App.2001) (addressing pro se appellant’s point relied on despite technical deficiency and general rule that pro se litigants must adhere to the same procedural requirements as lawyers because court was able to ascertain the issues and the arguments); Kennedy v. Missouri Attorney General, 922 S.W.2d 68, 70 (Mo.App.1996) (stating that in comparison to attorney prepared pleadings, a pro se petition is held to a less rigorous standard).

2002Cf. Moore v. Swisher Mower & Machine Co., Inc., 49 S.W.3d 731, 736-37 (Mo.App.2001) (addressing pro se appellant’s point relied on despite technical deficiency and general rule that pro se litigants must adhere to the same procedural requirements as lawyers because court was able to ascertain the issues and the arguments); Kennedy v. Missouri Attorney General, 922 S.W.2d 68, 70 (Mo.App.1996) (stating that in comparison to attorney prepared pleadings, a pro se petition is held to a less rigorous standard).

11
Ke-Wash Company v. Stauffer Chemical Companygreen
iowa · 1970 · cited in 1 Missouri opinions naming this issue, 1991–1991
1 sentence

1991Industrial Risk Insurers v. Creole Production Services, 568 F.Supp. 1323, 1328 (D.C.Alaska 1983); Ke-Wash Co. v. Stauffer Chemical Co., 177 N.W.2d 5, 10-11 (Iowa S.Ct.1970); and cases cited in those opinions.

11
INDUS. RISK INS'RS v. Creole Produc. Serv.green
akd · 1983 · cited in 1 Missouri opinions naming this issue, 1991–1991
1 sentence

1991Industrial Risk Insurers v. Creole Production Services, 568 F.Supp. 1323, 1328 (D.C.Alaska 1983); Ke-Wash Co. v. Stauffer Chemical Co., 177 N.W.2d 5, 10-11 (Iowa S.Ct.1970); and cases cited in those opinions.

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 (5)

CaseCitedYears
State v. Richard green
mo · 2009
2 sentences

2015Despite my disagreement about the appropriate standard of review to apply to article 1, section 23 challenges raised prior to the 2013 amendment, section 571.070 can be upheld under the less rigorous standard articulated in State v. Richard, 298 S.W.3d 529 (Mo. banc 2009), and State ex rel.

2015Despite my disagreement about the appropriate standard of review to apply to article 1, section 23 challenges raised prior to the 2013 amendment, section 571.070 can be upheld under the less rigorous standard articulated in State v. Richard, 298 S.W.3d 529 (Mo. banc 2009), and State ex rel.

22015–2015
Daugherty v. City of Maryland Heights green
mo · 2007
1 sentence

2009We are mindful of the changes brought by Daugherty and its admonition that “Missouri employment discrimination law in a post-MAI 31.24 environment should more closely reflect the plain language of the MHRA and the standards set forth in MAI 31.24 and rely less on analysis developed through federal caselaw.” Daugherty, 231 S.W.3d at 819 .

12009–2009
Biscoe v. Kowalski green
mo · 1956
1 sentence

1958For cases directly and impliedly recognizing excuses even though there was in fact a technical violation of the statute see Collins v. Beckmann, Mo., 79 S.W.2d 1052 ; Cantwell v. Cremins, 347 Mo. 836 , 149 S.W.2d 343 ; Biscoe v. Kowalski, Mo., 290 S.W.2d 133 ; Wilson v. Shumate, Mo., 296 S.W.2d 72 .

11958–1958
Cantwell v. Cremins green
· 1941
2 sentences

1958For cases directly and impliedly recognizing excuses even though there was in fact a technical violation of the statute see Collins v. Beckmann, Mo., 79 S.W.2d 1052 ; Cantwell v. Cremins, 347 Mo. 836 , 149 S.W.2d 343 ; Biscoe v. Kowalski, Mo., 290 S.W.2d 133 ; Wilson v. Shumate, Mo., 296 S.W.2d 72 .

1958For cases directly and impliedly recognizing excuses even though there was in fact a technical violation of the statute see Collins v. Beckmann, Mo., 79 S.W.2d 1052 ; Cantwell v. Cremins, 347 Mo. 836 , 149 S.W.2d 343 ; Biscoe v. Kowalski, Mo., 290 S.W.2d 133 ; Wilson v. Shumate, Mo., 296 S.W.2d 72 .

11958–1958
Wilson Ex Rel. Wilson v. Shumate green
mo · 1956
1 sentence

1958For cases directly and impliedly recognizing excuses even though there was in fact a technical violation of the statute see Collins v. Beckmann, Mo., 79 S.W.2d 1052 ; Cantwell v. Cremins, 347 Mo. 836 , 149 S.W.2d 343 ; Biscoe v. Kowalski, Mo., 290 S.W.2d 133 ; Wilson v. Shumate, Mo., 296 S.W.2d 72 .

11958–1958

Where else courts name it

TX 182 (1915–2026) IN 129 (1989–2025) CA 99 (1923–2026) OH 96 (1991–2025) LA 80 (1911–2022) NY 67 (1899–2026) IL 64 (1941–2025) OR 62 (1928–2026) FL 46 (1974–2025) NJ 39 (1976–2025) AL 39 (1917–2026) ID 34 (1972–2023) MA 32 (1973–2026) WA 30 (1944–2023) NC 28 (1913–2021) PA 28 (1925–2026) MD 23 (1925–2026) KS 22 (1879–2024) NV 22 (1996–2024) DC 21 (1952–2023) AR 20 (1893–2024) GA 20 (1983–2025) MI 19 (1919–2025) CT 19 (1976–2025) ND 18 (1982–2002) WI 18 (1923–2025) RI 17 (1983–2015) TN 17 (1931–2025) NM 16 (1978–2021) MN 15 (1972–2018) VT 14 (1980–2026) UT 14 (1933–2016) WY 14 (1893–2025) MO 13 (1958–2025) ME 13 (1972–2020) KY 13 (1946–2025) WV 11 (1909–2022) CO 11 (1995–2022) IA 11 (1915–2026) AZ 10 (1981–2026) VA 10 (1906–2020) AK 6 (1972–2011) DE 6 (1989–2026) NH 5 (1990–2018) MT 4 (1900–2016) OK 4 (2007–2023) MS 3 (1998–2018) SD 3 (2003–2013) HI 3 (1981–2009) NE 2 (1897–2004) SC 2 (1989–2018)

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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