Christian Disposal, Inc. v. Village of Eolia

Christian Disposal, Inc. (CDI) (plaintiff) provided trash-collection services for the Village of Eolia (defendant). Missouri law required a municipality getting into the public trash-collection business to give two years’ notice to the municipality’s current private trash collector. The purpose of this law was to afford the private trash collector the ability to make the necessary adjustments to its business. Pursuant to this statute, on March 9, 1993, the village gave notice to CDI that it would be terminating its service contract in two years. In this letter, the village also requested CDI’s trash-collection contracts with village residents and businesses pursuant to another Missouri law that stated that private trash collectors “shall make available” such information within 30 days of a written request to do so. CDI failed to provide the requested information to the village within 30 days. In response, the village determined that this failure meant that CDI was estopped from claiming the benefits of the two-year notice. Accordingly, the village notified CDI that it would be terminating their contract as of August 1, 1993. CDI sued the village for a declaratory ruling that the village violated the two-year-notice law. The trial court agreed with the village, finding that CDI was estopped from claiming the benefits of the two-year notice. CDI appealed.