Beatty v. Metropolitan St. Louis Sewer District
Missouri Supreme Court
867 S.W.2d 217 (1993)

- Written by Sean Carroll, JD
Facts
Prior to 1954, various public and private entities provided sewer services in St. Louis County. In 1954, voters approved the Metropolitan St. Louis Sewer District (MSD) (defendant) to provide sewer services to most residents and businesses in the county. MSD charged its customers a quarterly flat rate. Only 9,000 of the 420,000 properties in the county did not use MSD’s services. These properties did not pay MSD’s quarterly fees. When MSD attempted to raise its sewer rates, Beatty (plaintiff) sued MSD, arguing that the fee could not be increased without voter approval. Beatty relied on an amendment to the Missouri Constitution that prohibited municipalities from increasing government-imposed taxes without voter approval. The trial court ruled that MSD’s rate was not subject to voter approval and could be raised without such approval. The court of appeals reversed and then, en banc, referred the case to the Missouri Supreme Court.
Rule of Law
Issue
Holding and Reasoning (Robertson, J.)
Concurrence (Holstein, J.)
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