Gurley v. Mo. Bd. of Private Investigator Exam'rs
Annotate this CaseIn 2007, the General Assembly enacted a series of statutes regulating the private investigator profession. Appellant subsequently applied for licensure as a private investigator. The Board of Private Investigator Examiners initially denied Appellant's application, but later the Administrative Hearing Commission ordered the board to grant Appellant a license. After Appellant was awarded a license, he continued to pursue a lawsuit he had filed against the board and its members, arguing that the statutory scheme violated the free speech clauses of the state and federal constitutions and that his procedural due process rights were violated when the board denied his application before giving him a meaningful opportunity to be heard. The circuit court (1) dismissed Appellant's procedural due process claim as moot, and (2) dismissed Appellant's free-speech claims after concluding that the statutes were not unconstitutional on their face. The Supreme Court affirmed, holding that the circuit court did not err in its judgment.
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