In a unanimous opinion, the Court made its preliminary writ of prohibition permanent in a writ proceeding arising from a putative class action against the City of St. Louis. The Court held that sovereign immunity bars money had and received claims against a public entity unless the legislature has authorized the suit, and that section 432.070, which requires municipal contracts to be written, signed, and authorized, also bars claims resting on implied-in-fact contracts. Roberts’s claim that the City owed refunds for recycling and yard waste collection it did not separately provide amounted to an implied-in-fact contract claim, and the Court rejected her proprietary-function argument because garbage collection is a governmental function even when the City charges a fee for it.
