Missouri Supreme Court Mandates the Houston Four-Step Framework for Against-the-Weight-of-the-Evidence Appeals

1. Introduction

Weeks v. City of St. Louis (Supreme Court of Missouri, Nov. 4, 2025) arises from a dispute under Missouri’s Sunshine Law over what, precisely, a public record custodian must produce when the requester seeks traffic-stop data in a particular “spreadsheet” presentation. The St. Louis Metropolitan Police Department collected traffic stop data under § 590.650 and stored it in computerized .CSV files. Michael Weeks emailed a Sunshine Law request seeking “files of the databases” for 2014–2018, including officer identifiers, and clarified he wanted the database “in spreadsheet formatting (preferably in excel).”

The Department offered to produce a large set of traffic analysis reports with redacted identifiers at a cost; Weeks declined and sued, alleging a knowing and purposeful Sunshine Law violation. In discovery, the City produced .CSV files. Weeks testified the .CSV files were “exactly” in the format he requested, but also testified he specifically wanted an Excel spreadsheet format. The circuit court entered judgment for the City, finding it did not “hold or maintain an existing record responsive” to Weeks’ “specific request” (i.e., a spreadsheet-format record). On appeal, Weeks asserted only that the judgment was against the weight of the evidence.

The decision’s lasting importance is less about the Sunshine Law merits and more about appellate methodology: the Court expressly adopted a mandatory four-step analytical framework—previously developed and applied in the court of appeals—for “against-the-weight-of-the-evidence” challenges.

2. Summary of the Opinion

The Supreme Court of Missouri affirmed the judgment for the City. It held Weeks’ appellate argument failed because he did not properly analyze an against-the-weight-of-the-evidence claim using the required analytical steps. In doing so, the Court expressly adopted the Houston v. Crider four-step framework as the governing method for these challenges.

The Court also rejected Weeks’ contention that the City made a conclusive Rule 59.01 admission that it possessed “responsive” records. The City admitted only that it did not produce .CSV files in response to the request—not that such files were “responsive” to the specific request for spreadsheet-format records. The circuit court’s finding—that the City had the data but not an existing spreadsheet-format record—was consistent with that admission.

3. Analysis

A. Precedents Cited

• Murphy v. Carron, 536 S.W.2d 30 (Mo. banc 1976)
  The Court began with the foundational standard for reviewing a bench-trial judgment: reversal is permitted only if there is no substantial evidence, the judgment is against the weight of the evidence, or the judgment erroneously declares/applies the law. This structure matters because it frames “against the weight” as one distinct route among several, each requiring its own analysis.
• Ivie v. Smith, 439 S.W.3d 189 (Mo. banc 2014)
  Ivie supplies the modern articulation of what an “against-the-weight” review entails: the appellate court presupposes substantial evidence supports the judgment and asks whether the trial court could reasonably find a fact necessary to sustain the judgment. Ivie also emphasizes deference to credibility determinations and explains that when evidence supports two reasonable conclusions, the appellate court must defer to the trial court. Critically, the Court used Ivie to underscore that Weeks did not raise (and therefore did not preserve for review) a “misapplied law” claim—only “weight of the evidence.”
• Pearson v. Koster, 367 S.W.3d 36 (Mo. banc 2012)
  This case is cited for the practical reality that reversals on “against the weight” grounds are rare, emphasizing the uphill nature of Weeks’ chosen appellate posture.
• State Farm Mut. Auto. Ins. Co. v. Allen, 744 S.W.2d 782 (Mo. banc 1988)
  The Court invoked this decision to reinforce that trial-court factfinding in a bench trial receives the “approximate effect of a jury verdict,” particularly where credibility and weighing are involved.
• Houston v. Crider, 317 S.W.3d 178 (Mo. App. 2010)
  This is the centerpiece precedent. The Court not only relied on Houston’s four-step framework but expressly adopted it. The framework requires appellants to: (1) identify a challenged factual proposition necessary to sustain the judgment; (2) identify all favorable evidence supporting that proposition; (3) identify contrary evidence while resolving conflicts consistent with the trial court’s credibility determinations; and (4) demonstrate the favorable evidence is so lacking in probative value that it fails to induce belief when viewed in the whole record. The Court’s adoption converts what had been a court-of-appeals discipline into a Supreme Court-mandated methodology.
• Bell-Kaplan v. Schwarze, 712 S.W.3d 836 (Mo. App. 2025); Riead v. Riead, 685 S.W.3d 532 (Mo. App. 2023); O.H.B. ex rel. S.M.B. v. L.Y.S., 665 S.W.3d 329 (Mo. App. 2023); Wille v. Curators of Univ. of Mo., 627 S.W.3d 56 (Mo. App. 2021); Schubert v. Schubert, 561 S.W.3d 787 (Mo. App. 2018); APAC-Mo., Inc. v. Boyer, 420 S.W.3d 651 (Mo. App. 2013); Halverson ex rel. Sumners v. Halverson, 362 S.W.3d 443 (Mo. App. 2012)
  These cases are deployed to show that, for years, the court of appeals has treated the Houston framework as “mandatory” and has routinely rejected “against-the-weight” arguments that do not perform the required steps. The Supreme Court’s opinion effectively validates and constitutionalizes (within Missouri’s judicial hierarchy) that appellate practice.
• Buckner v. Jordan, 952 S.W.2d 710 (Mo. banc 1997)
  Buckner is cited as an example of the rare case where reversal on weight-of-the-evidence grounds was warranted because the trial court failed to consider evidence on a critical fact (parental income) central to child support. The Court used Buckner to distinguish Weeks’ Rule 59.01 argument: unlike Buckner, there was no overlooked dispositive evidence or admission here.

B. Legal Reasoning

The Court’s reasoning proceeds in two layers: (1) defining the appellate task Weeks actually invoked; and (2) finding his briefing failed to do it. Because Weeks raised only an “against the weight of the evidence” point, the Court treated substantial evidence as presumed and focused on whether the circuit court could reasonably find the City lacked an existing record responsive to the “specific request” for spreadsheet-format records.

The Court then treated the briefing failure as fatal. Weeks identified the challenged factual proposition (the City lacked an existing responsive record), but did not complete the remaining steps required by Houston v. Crider:

• He did not identify all favorable evidence supporting the circuit court’s finding—e.g., evidence supporting the view that his request demanded a spreadsheet-format record the Department did not maintain.
• He emphasized contrary evidence (including the later-produced .CSV files) without resolving conflicts in the manner required by deference to the trial court’s credibility determinations—particularly in light of Weeks’ own testimony that he “wanted it in spreadsheet formatting.”
• Without steps two and three, he could not coherently perform step four: demonstrating that the favorable evidence was so lacking in probative value that the trial court could not reasonably believe it.

On the Rule 59.01 point, the Court carefully constricted the admission to what was actually admitted: the City conceded it did not produce .CSV files in response to the request, not that it possessed “responsive” records meeting the request’s spreadsheet-format demand. The circuit court’s finding—data existed, but not an existing spreadsheet-format record—therefore did not “ignore” a conclusive admission.

C. Impact

Appellate practice impact (primary): The decision cements the Houston v. Crider framework as the Supreme Court’s endorsed, structured method for “against-the-weight” claims. Practically, it raises the floor for appellate briefing: failing to inventory favorable evidence, address contrary evidence through the lens of credibility deference, and explain probative insufficiency across the whole record will routinely doom the point on appeal.

Sunshine Law/records-format impact (secondary): Although the Court framed the case as a weight-of-the-evidence dispute rather than a pure Sunshine Law interpretation, the outcome underscores a litigation reality in public-records disputes: the precision of the request—especially about format (“spreadsheet formatting (preferably in excel)”)—can become dispositive if the public body credibly establishes it does not “hold or maintain” an existing record in the demanded form. Requesters may respond by drafting format language to avoid inadvertently narrowing the request, while agencies may more clearly document what formats are maintained versus what would require conversion or creation.

Rule 59.01 impact: The opinion also cautions litigants against overreading admissions: a Rule 59.01 admission is conclusive only as to the fact admitted, not the broader characterization (“responsive”) a party wishes it to imply.

4. Complex Concepts Simplified

• “Against the weight of the evidence”: Not a re-trial on appeal. The appellate court largely defers to the trial judge on credibility and weighing; reversal occurs only when the trial judge could not reasonably have found a necessary fact.
• The Houston four-step framework: A structured checklist for making (and evaluating) a “weight of the evidence” argument. It forces the appellant to confront (not ignore) evidence that supports the judgment and to explain why that evidence is too weak to believe.
• Bench trial deference: Even without a jury, the trial judge’s factual findings are treated much like a jury verdict on appeal.
• Rule 59.01 admission: A formal admission that conclusively establishes a specific fact against the admitting party—but only the fact actually admitted, not an expanded interpretation.
• .CSV vs. “Excel spreadsheet”: A .CSV is a data file format often opened in spreadsheet programs, but a request for an “Excel spreadsheet” can be understood as demanding a specific maintained spreadsheet-format record (not merely data exportable into one), depending on the evidence and the trial court’s credibility findings.

5. Conclusion

Weeks v. City of St. Louis affirms a defense judgment in a Sunshine Law dispute, but its enduring significance is procedural: the Supreme Court of Missouri expressly adopts the Houston v. Crider four-step analytical framework for “against-the-weight-of-the-evidence” challenges and signals that noncompliant briefing will fail. The opinion reinforces strict deference to trial-court factfinding and credibility determinations, and it illustrates how the scope and specificity of a records request—especially regarding format—can become outcome-determinative when the appeal is limited to weight-of-the-evidence review.