## Facts

- St. Louis County, a first-class county, adopted a home-rule charter and ordinances creating a county personnel system.
- The charter framework purported to place county officials in control of hiring, supervision, and removal of employees working in the juvenile court’s administration and detention departments.
- County officials also claimed authority to set the number of those employees and fix their compensation.
- The juvenile court judge challenged the county’s asserted authority as an invasion of judicial power under the Missouri Constitution and as inconsistent with the statewide Juvenile Code.
- The action was brought in the Missouri Supreme Court as an original proceeding in quo warranto seeking to oust county officials from exercising the contested powers.

## Issues

1. Whether the juvenile court or the county has authority to select and control personnel serving the juvenile court’s administration and detention departments.
2. Whether the juvenile court or the county has authority to determine the number of employees in those departments.
3. Whether the juvenile court or the county has authority to fix compensation for those employees consistent with separation of powers and applicable statewide law.

## Decision

- The court held that selection and control of personnel in the juvenile court’s administration and detention departments is a judicial function that must remain under the juvenile court judge, not county authorities.
- The court held the juvenile court must have effective authority regarding the number of necessary employees and their compensation to the extent required for the court to perform its duties, subject to reasonable funding and general classification measures that do not impair court operations.
- The court ruled the county charter and ordinances were invalid to the extent they transferred these powers to county officials and interfered with essential judicial functions.
- The court granted quo warranto relief and ousted the county and its officers from exercising the challenged authority over juvenile court personnel.

## Legal Principles

- Courts possess inherent authority to take measures reasonably necessary to perform their constitutional and statutory duties, including securing and directing essential staff.
- Separation of powers prohibits executive or legislative officials from exercising powers that properly belong to the judiciary, including operational control that compromises judicial independence.
- A county home-rule charter is subordinate to the state constitution and statewide statutes and cannot reassign or assume inherently judicial powers.
- Appropriations and general pay structures may be set through legislative or authorized local fiscal processes, but fiscal control cannot be used to deprive courts of necessary personnel or place core court staff under external operational control.

## Conclusion

The Missouri Supreme Court invalidated St. Louis County’s attempt to control juvenile court administration and detention staffing through its charter-based personnel system, holding that separation of powers and inherent judicial authority require the juvenile court to control essential personnel and to obtain staffing and compensation sufficient for the court to function.


State ex rel. Weinstein v. St. Louis County, 451 S.W.2d 99 (Mo. 1970)