A Missouri gun range has finally come out on top of a decades-long legal battle dating back to the 1980s, after the Missouri Supreme Court upheld a lower court’s decision to end an injunction that had placed tight controls on the range’s ability to operate.
Fifty years ago the Glendale Shooting Club acquired some property with the intent of operating a range. A family living adjacent to the property weren’t thrilled with the prospect of gunfire coming from the club, and eventually filed suit claiming the persistent pew-pewing affected their property.
In 1987 a judge on the Franklin County Circuit Court issued a permanent injunction that restricted Glendale’s operations, including limiting the number of competitions, shooters, hours of use, and restricting the use of firearms over a certain caliber as well. A Missouri Court of Appeals upheld the injunction, and in 1989 the family ended up selling their property to the Landolt family.
In the 1990s, Missouri lawmakers adopted a law granting firearm ranges immunity from noise-based nuisance actions. Glendale first filed a motion to dissolve the injunction in 1998, but was denied in circuit court. An appellate court reversed that decision, however, and remanded the case back to the circuit court for a do-over.
Before that could happen, Glendale and the Landolt family entered into a settlement that included a clause prohibiting litigation from either party for a period of 20 years.
When that agreement expired, Glendale once again sought to have the injunction dissolved. This time the circuit court agreed with the gun club, and it was the Landolt who appealed, arguing that the state’s range protection statute was a violation of the Missouri Constitution. Without delving into the constitutional question, the state Supreme Court decided that the lower court had failed to “properly weigh the equities” between the two parties and once again remanded the case back to circuit court.
After that, the circuit held a full trial and once again concluded that the injunction should be dissolved. The Landolts appealed once again as well, and last week the Missouri Supreme Court finally put the case to rest by upholding the lower court decision dissolving the injunction.
The circuit court’s judgment in setting aside the injunction, however, did not exclusively rely on the change of law provided in section 537.294. The circuit court also found an alternative ground rendering continued enforcement of the injunction inequitable. Specifically, the circuit court found the recent changes Glendale made to its property regarding the use of the firearm ranges mitigated the noise that could be heard on the Landolts’ property. These changes included the construction of sound barriers on top of the berms surrounding the various shooting ranges. Together these berms and barriers created a “sound shadow” reducing the noise level from gunfire on the range.
The circuit court weighed the evidence both parties presented and found the changes reduced the noise level to no longer qualify as a nuisance, at least comparatively with other county ordinances.
It’s wild to me that the range protection statute wasn’t necessarily enough, by itself, to halt the injunction. At the same time, it’s worth noting that the Glendale Shooting Club undertook these range improvements on its own, without any court order. Maybe club members wanted to be good neighbors, or maybe they were just hoping that the courts would look favorably on their actions, but in either case the range no longer has to operate under court-ordered rules put in place back when Ronald Reagan was president and acid-washed jeans were the style of the day.
As Second Amendment Foundation investigative journalist Lee Williams wrote back in 2024, the terms of the injunction were pretty severe.
- No shooting before 9 AM or after dark or 6 PM
- No more than 10 shooting matches per year, and only two high-power rifle matches.
- No more than two matches in any one month, and only one on a Sunday.
- No more than 8 persons can shoot at one time during a pistol match.
- No more than 8 persons can shoot at any time, club-wide, other than during a rifle match.
- No shooting of shotguns or firearms of a caliber greater than a .22 except between 9 AM and 6 PM on Tuesdays, Thursdays, and Saturdays, and during a rifle match.
Williams wrote that membership cratered after the injunction was put in place, and hasn’t really recovered since. As of 2024, Glendale had just 140 members, who collectively have spent more than $300,000 in their legal fight.
Now that the decades-long legal battles are over, I hope that Glendale Shooting Club can have a renaissance. At the moment, I’m not sure it even has a website, but given its proximity to St. Louis I imagine there are number of nearby gun owners who would love to become a member and help rebuild and restore the club to its former glory.
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