Equitable Limits of Rule 74.06(b)(5): Change in Law Not Sole Basis for Relief

Introduction

In City of Normandy v. Mike Kehoe (Mo. banc, Apr. 15, 2025), the Supreme Court of Missouri clarified the narrow circumstances under which a party may obtain relief from a final judgment that imposed injunctive relief. In 2015, the General Assembly enacted Senate Bill 5, which included sections 67.287 and 479.359.2 limiting certain municipal revenue and imposing standards on municipalities in St. Louis County. In 2016, the Circuit Court of Cole County declared those provisions unconstitutional under article III, section 40 of the Missouri Constitution and permanently enjoined their enforcement. This Court affirmed in City of Normandy I (518 S.W.3d 183, 202 (Mo. banc 2017)). After this Court reinstated a rational‐basis test for “local or special law” challenges in City of Aurora (592 S.W.3d 764 (Mo. banc 2019)), the State sought relief from the injunction under Missouri Rule of Civil Procedure 74.06(b)(5), arguing that the doctrinal shift rendered continuation of the injunction inequitable. The circuit court initially granted relief but this Court vacated that order in City of Normandy II (643 S.W.3d 311, 318 (Mo. banc 2022)). On remand, the circuit court denied the motion, and today’s decision affirms that denial.

Summary of the Judgment

The Supreme Court, writing for an en banc bench, affirmed the circuit court’s denial of the State’s motion for relief under Rule 74.06(b)(5). Key holdings include:

The proper standard of review is abuse of discretion for equitable motions under Rule 74.06(b)(5).
A post‐judgment change in decisional law—here, the shift to rational‐basis review in City of Aurora—is neither necessary nor sufficient to warrant relief from a permanent injunction.
The doctrine of law of the case bars relitigation of the 2016 declaratory judgment that the statutes violated article III, section 40.
The principle of finality protects judgments from casual reopening; only narrow exceptions, grounded in equity, permit relief.
The declaratory judgment that the statutes are unconstitutional remains in effect; injunctive relief is merely a remedy enforcing that declaration.
Lifting the injunction would unfairly deprive municipalities of the statutory grace periods the legislature initially provided.

Analysis

Precedents Cited

City of Normandy I (518 S.W.3d 183): Declared sections 67.287 & 479.359.2 unconstitutional under article III, section 40 and enjoined enforcement.
City of Aurora (592 S.W.3d 764): Overruled the closed‐ended/open‐ended test and reinstated a rational‐basis analysis for “local or special law” challenges.
City of Normandy II (643 S.W.3d 311): Held that a change in decisional law alone does not justify relief under Rule 74.06(b)(5) and remanded for an equitable balancing of factors.
Glendale Shooting Club (661 S.W.3d 778): Reinforced the narrow scope of Rule 74.06(b)(5), requiring proof of inequity beyond legal changes.
Henry v. Piatchek (578 S.W.3d 374) & Board of Education v. Missouri State Board of Education (271 S.W.3d 1): Established the abuse of discretion standard for Rule 74.06(b) motions.
Law-of-the-case authorities such as American Eagle Waste Industries, LLC (379 S.W.3d 813) and finality pronouncements in Goldsmith v. M. Jackman & Sons, Inc. (327 F.2d 184–85).

Legal Reasoning

The Court’s decision rests on three interlocking principles:

Finality and Law-of-the-Case: Once the 2016 judgment declared the statutes unconstitutional, that ruling became the law of the case. Subsequent doctrinal shifts cannot reopen settled issues without equitable justification.
Equitable Discretion under Rule 74.06(b)(5): Relief from a prospective injunction demands a showing that “it is no longer equitable that the judgment remain in force.” A changed legal analysis alone does not satisfy the equitable standard; courts must weigh competing considerations such as reliance interests, burdens, and the nature of the remedy.
Remedy Versus Cause of Action: The declaratory judgment invalidating the statutes stands independently. An injunction is the mechanism enforcing that declaration. The State never sought relief from the underlying declaration, so no statute remains to enforce—even if the injunction were lifted.

Impact

This decision cements an equity‐based framework for post-judgment relief in Missouri. Litigants can no longer rely solely on changes in law to vacate injunctions; they must demonstrate actual inequity. The ruling will:

Protect the stability and finality of judicial determinations.
Require courts to conduct a fact-specific, equity-driven analysis before modifying or vacating injunctive relief.
Encourage parties to challenge the substantive validity of statutes directly rather than via collateral motions.

Complex Concepts Simplified

Rule 74.06(b)(5): Allows a court to relieve a party from a prospective judgment when maintaining it is inequitable; demands more than a mere shift in case law.
Article III, Section 40: Missouri Constitution’s bar on “local or special laws”; historically tested by varying frameworks.
Rational‐Basis Analysis: Asks whether a legislative classification is rationally related to a legitimate purpose.
Closed-Ended/Open-Ended Test: A former doctrinal approach distinguishing laws that applied to specifically named entities (closed) versus broader classes (open).
Law-of-the-Case Doctrine: Precludes relitigation of questions decided earlier in the same proceeding.
Declaratory Judgment vs. Injunction: A declaratory judgment pronounces rights or invalidates laws; an injunction enforces that declaration by commanding or prohibiting action.

Conclusion

City of Normandy v. Kehoe underscores that the equitable discretion embodied in Rule 74.06(b)(5) cannot be evoked by a changed doctrinal landscape alone. The principles of finality, reliance, and separation of remedy from substantive holdings demand a fact-specific inquiry into inequity. This decision will guide future litigants and courts, ensuring that only narrow, compelling circumstances can unsettle final injunctive decrees.