Mootness, Exceptions

Courts generally shy away from rendering decisions in moot cases. A case is moot when “the question presented for decision seeks a judgment upon some matter which, if the judgment was rendered, would not have any practical effect upon any then existing controversy.” DCM v. Pemiscot County Juvenile Office, 578 S.W.3d 776, 780 (Mo. 2019).

There are at least two major exceptions to mootness, both of which are discretionary. First, a court may here cases presenting circumstances that are “capable of repetition, yet evade review.” Gramex Corp. v. Von Romer, 603 S.W.3d 521 (Mo. 1980) (where the Missouri Supreme Court reviewed legalities relating to an election and still decided the case after the election occurred). Second, a court can here cases involving collateral legal consequences. In Interest of JTS, 462 S.W.3d 475, 479 (Mo. App. W.D. 2015); see In Interest of NRW, 482 S.W.3d 473, 475 (Mo. App. E.D. 2016) (a juvenile became an adult during a criminal proceeding, but the Court still reviewed because the adjudication could have significant collateral consequences for the juvenile into his adult life).