¶1concurring.
¶2I concur with the principal opinion. I write separately to emphasize that this case is about conduct, not speech. In my view, In re Westfall, 808 S.W.2d 829 (Mo. banc 1991), which involved only speech, was decided wrongly.
282 S.W.3d 350
In Re Madison
Decided May 5, 2009
Supreme Court of Missouri · decided 2009-05-05
Relies on Matter of Westfall
Good law ✅— No negative treatment on recordhow we know
Decided 2009-05-05
How this case has been cited
Cited by 6 later decisions — most recently December 2025
6 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
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