Eastern District clarifies when the statute of limitations begins to run under the Law Enforcement Officer Bill of Rights

The Missouri Legislature passed Section 590.502, which is commonly referred to as the Law Enforcement Officer’s Bill of Rights (“LEOBOR”), in 2021. LEOBOR states that “[a] lawsuit for enforcement shall be brought within one year from which the violation is ascertainable.” Section 590.502(10). In one of the few cases interpreting LEOBOR, Rumpsa v. Jefferson Cnty. Sheriff’s Dept., et al.¸ No. ED113002 (Sept. 2, 2025), the Eastern District recently determined when a violation is ascertainable for the one-year statute of limitations.

In Rumpsa, the plaintiff filed his petition in Circuit Court on July 11, 2023. In that petition, he alleged 3 violations of LEOBOR: (1) failing to provide him with the complaint prior to his interview, which was conducted on May 21, 2022; (2) failing to give him seven days’ notice of the due process hearing, which occurred on July 8, 2022; and (3) defendants failure to call witnesses and present evidence at the due process hearing. After the hearing, the plaintiff appealed his termination to the Merit Commission. The plaintiff was notified on July 14, 2022 that the Merit Commission upheld his termination.  

The defendants argued that the plaintiff filed his petition outside of the one-year statute of limitations because any alleged violation would have been ascertainable on July 8, 2022, at the latest. The Eastern District agreed and held that the one-year statute of limitations begins to run “when the violation could have been discovered or was made known, or when a reasonable person would have been put on notice that a violation may have occurred and would have undertaken to ascertain the extent of the violation.”  

The court determined that the plaintiff filed his petition outside the one-year statute of limitations because a reasonable person would have been on notice on each of the above dates that a violation may have occurred. Ultimately, the Merits Commission decision to uphold the termination was inconsequential because the plaintiff could have ascertained each of his three alleged violations by July 8, 2023, at the latest.  

Municipalities should keep the Rumpsa case in mind in any future litigation regarding LEOBOR.