Raytown Ward 3 Alderman Latrice Thomas

08/22/2026

On Tuesday, August 25, 2026, at 6:30 p.m., the Raytown Board of Aldermen will meet to sit as a Board of Impeachment at City Hall.

View the agenda online: https://www.raytown.mo.us/government/boards_commissions/board_of_aldermen.php

08/13/2026

THE JUNE 26, 2025 REMOVAL

On June 26, 2025 at 11:00 a.m., Jackson County Election Board Director Tammy Brown emailed a copy of the June 10, 2025 DOR letter directly to Mayor Michael McDonough and City Clerk Henry.

At 12:41 p.m. that same day, Henry forwarded the letter to City Attorney Baird "for review and comment." Baird drafted a removal letter, which was reviewed and approved by Baird and then signed by Mayor McDonough.

At 1:32 p.m., before the removal letter had even been delivered to Thomas, Henry emailed IT staff instructing: "Latrice Thomas has been disqualified from holding public office at this time. Please shut down her city email and remove her from the governing body email group."

Sometime after 1:32 p.m., Mayor McDonough personally met with Thomas, handed her the signed removal letter along with a copy of the DOR letter, and confiscated her city-issued iPad and keycard, removing her from the Ward 3 Alderwoman seat.

At 2:34:43 p.m., Henry emailed the full Board of Aldermen, the Mayor, City Administrator Diane Egger, and Records, attaching the disqualification packet and stating it had been "hand delivered to Latrice Thomas today during a meeting with Mayor McDonough." This was the Board's first notice of the removal — after it had already occurred.

At 2:34:50 p.m. — seven seconds after that Board-wide email — a remote wipe of Thomas's city-issued iPad was completed (Device ID: EAE9D50NTT30T6OC2K7AFJ6EPO), per an automated "Remote Device Wipe Confirmation" record.

No Board of Aldermen vote authorized, preceded, or in any way accompanied the June 26, 2025 removal. Section 79.240 RSMo requires Board consent to remove a duly elected alderman.

No quo warranto action — the proper statutory remedy under Section 531.010 RSMo for challenging an elected official's qualifications after taking office — was ever initiated by the Attorney General or the Jackson County Prosecutor regarding Thomas's eligibility.

08/12/2026

Who Is Baird's Client?
Everything flows from this threshold question, and the answer under Missouri law and legal ethics rules is unambiguous: Baird's client is the City of Raytown as a governmental entity — not the mayor, not the city administrator, not the city clerk, and not any individual alderman.
This principle is codified in Missouri Rule of Professional Conduct 1.13, which governs representation of organizational clients:
"A lawyer employed or retained by an organization represents the organization acting through its duly authorized constituents."
The comment to Rule 1.13 makes the implication explicit: when the interests of constituents — officers, employees, officials — diverge from the interests of the organization itself, the attorney's duty runs to the organization. The organization, not the constituent who happens to be directing the attorney at any given moment.
For a municipal government, the "organization" is the city. The city's interests are ultimately expressed through its governing body — the Board of Aldermen — not through the mayor or city administrator alone. This is especially true in a mayor-council form of government like Raytown's, where legislative authority is vested in the board and the mayor's executive authority is defined and limited by statute.

This is the provision Baird appears to have ignored entirely, and it is not discretionary. Rule 1.13(b) states:
"If a lawyer for an organization knows that an officer, employee or other person associated with the organization is engaged in action, intends to act or refuses to act in a matter related to the representation that is a violation of a legal obligation to the organization, or a violation of law that reasonably might be imputed to the organization, and that is likely to result in substantial injury to the organization, then the lawyer shall proceed as is reasonably necessary in the best interest of the organization."
Parse that carefully. The rule applies when:
An officer or employee is engaged in action that violates a legal obligation to the organization or violates law that might be imputed to the organization
And that action is likely to result in substantial injury to the organization
Both conditions are clearly met in Raytown's situation. McDonough's unilateral June 26 removal violated § 79.240 RSMo — a legal obligation to the organization. Egger's unauthorized retention of Garrett without board approval violated the city's own procurement obligations. Henry's participation in drafting the removal letter, directing it through Baird, and withholding records in response to Thomas's requests exposes the city to Sunshine Law liability. All of these actions are likely to result in substantial injury to the organization — specifically: § 1983 liability, back pay obligations, defamation exposure, and the legal fees already being incurred.
When these conditions are met, Rule 1.13(b) says the lawyer shall — mandatory, not discretionary — proceed in the best interest of the organization. The rule then specifies what that means:
"the lawyer shall refer the matter to higher authority in the organization, including, if warranted by the circumstances, to the highest authority that can act on behalf of the organization as determined by applicable law."
In a municipal government, the highest authority is the Board of Aldermen. Not the mayor. Not the city administrator. The board.
Baird was obligated — under mandatory professional conduct rules — to bring this matter to the full board's attention the moment she understood that the mayor's June 26 action created legal exposure for the city. The Teresa Henry letter establishes that Baird was involved in drafting the June 26 removal letter. That means she had contemporaneous knowledge of the action and its legal basis — or lack thereof. Her obligation under Rule 1.13 attached at that moment.

The Attorney's Advisory Role

A city attorney advising a municipal client absolutely has both the authority and the obligation to advise the governing body when staff conduct creates legal exposure. This is a core function of municipal legal counsel — risk management through legal advice. The board cannot make informed governance decisions about personnel if the attorney withholds information about legal exposure created by those personnel.
The practical scope of this obligation includes:
Advising the board when an employee's actions exceed their authorized scope and create ultra vires liability for the city. Egger retaining Garrett without board authorization is a textbook example — Baird was aware of this and had an obligation to advise the board that the engagement was potentially unauthorized.
Advising the board when an employee's conduct in handling personnel matters creates discrimination, due process, or civil rights exposure. The June 26 removal process — no hearing, no vote, no notice — implicates all three.
Advising the board when the city clerk's handling of Sunshine Law requests creates liability under Chapter 610. Given Wyrick v. Henry — in which Baird's own firm's predecessor counsel was involved — Baird had specific knowledge of Henry's prior adjudicated violations and should have recognized the same pattern recurring.

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08/12/2026

UNLAWFUL PROCUREMENT AND RETENTION OF SPECIAL COUNSEL

Raytown's Code of Ordinances, Section 2-338 ("Authority to employ special counsel"), states in full: "If deemed in the best interest of the city, the board of aldermen may, by ordinance, employ special counsel to represent the city and to fix the compensation therefor."

Section 2-338 vests this authority in the Board of Aldermen, exercised by ordinance, with compensation fixed in that ordinance. City Administrator Diane Egger, not the Board, retained Special Counsel Graves Garrett Greim LLC (Nathan Garrett); no ordinance employing Garrett or fixing his compensation was ever passed. (CONFIRM exact retention date — Thomas received a letter from Garrett in December 2025; there is no documentation of Egger's actual engagement of the firm, beyond Henry's February 19, 2026 memo describing Egger's contact with the Attorney General's office and subsequent retention of Garrett.)

On January 6, 2026, the Board authorized $161,000 in legal/special counsel spending for FY2025-26 through resolution R-3781-26 — a resolution, not an ordinance, and one that did not name Graves Garrett Greim LLC specifically.

A bloc of aldermen (Emerson, Krizek, Mims, Hayden) attempted to keep R-3781-26 on the consent agenda, where it would have passed without discussion; the item was pulled for open discussion only after other aldermen objected.

On February 3, 2026, the Board passed R-3785-26 — again a resolution, not an ordinance — titled in part: "A RESOLUTION APPROVING AN AGREEMENT WITH GRAVES GARRETT GREIM LLC FOR SPECIAL COUNSEL SERVICES AND APPROVE AND RATIFY THE EXPENDITURE OF FUNDS WITH GRAVES GARRETT GREIM LLC IN EXCESS OF $30,000.00."

The word "ratify" in R-3785-26's own title is the City's acknowledgment that funds had already been expended with Graves Garrett Greim LLC before the Board approved that vendor on February 3, 2026. Garrett was retained and actively working the matter well before that date — his first appearance before the Board came two weeks later, at the February 17, 2026 first reading — meaning the City spent public money with an unauthorized vendor for a period of at least several weeks, and likely longer, before any Board action (by resolution, let alone the ordinance Section 2-338 requires) occurred.

R-3785-26 was placed on the February 3, 2026 consent agenda (item 2b) rather than the regular agenda, scheduling it for passage without individual discussion unless an alderman objected.

Neither R-3781-26 nor R-3785-26 satisfies Section 2-338's requirement that special counsel be employed "by ordinance" with compensation "fixed therein" — both were resolutions, a different and lesser legislative instrument under Raytown's own code.

08/12/2026

STRUCTURAL DEFECT UNDERLYING THE ENTIRE PROCESS

The impeachment proceeding is built on the premise that Thomas was ineligible to serve under Section 115.306 RSMo, a statute that by its own terms governs candidate qualification and disqualification at the time of filing for office, not the removal of an official after election and swearing-in. Elad Gross's July 11, 2025 letter to the City raised this same point, citing Davenport v. Teeters and Kasten v. Guth.

The proper legal mechanism for challenging an elected official's qualifications after taking office is a quo warranto action under Section 531.010 RSMo, brought by the Attorney General or County Prosecutor — a process the City did not pursue

Because the underlying June 26, 2025 removal was never authorized by a Board vote as required under Section 79.240 RSMo (see companion document, Part II), the entire impeachment process — improper retention of counsel, closed-session review, first and second readings, and any future hearing — proceeds from a predicate act the City's own counsel has acknowledged, on the record, never actually took legal effect.

08/12/2026

CONFLICTS OF INTEREST AND PREJUDGMENT AMONG DECISION-MAKERS

Mayor McDonough personally carried out the June 26, 2025 removal of Thomas. Per the official minutes, immediately after the ordinance passed on April 14, 2026, the Board — on a separate motion by Mims, seconded by Krizek — voted 9-0-1 to make McDonough the signatory on documents related to the impeachment hearing, including subpoenas. This places the official whose own June 26, 2025 conduct is centrally at issue in the position of administering the proceeding meant to review it.

At the November 11, 2025 meeting, Alderwoman Krizek told the public Thomas "swore that she had paid her taxes. She didn't" — a public statement of Thomas's guilt on the central factual question months before any impeachment hearing, evidentiary process, or subpoenaed records existed to support that conclusion.

Per the official minutes of the April 14, 2026 meeting, Alderman Mims stated in open session that she had ex parte communication regarding the impeachment item, then, seconded by Emerson, made the motion to adopt the ordinance herself. The substance of that ex parte communication was Mims personally advising Thomas to resign and sit out two years before running again. Mims thus disclosed a private communication with the person under consideration and then moved to adopt the very ordinance concerning her.

Alderman Jim Aziere stated at the April 14, 2026 meeting that he had gone to Jefferson City to meet with Attorney General Catherine Hanaway and Missouri Senate members (including Senator Cierpiot) regarding the Thomas matter before the vote; Krizek's May 2, 2026 Facebook post confirms this account and adds that Aziere was advised that failing to vote for a hearing "sets a precedent that we don't uphold the law." This is sourced to Aziere's own in-meeting statement and Krizek's public recounting of it — not yet to any written record of the Jefferson City meeting itself.

Bill No. 6707-26 requires "a simple majority vote of all elected members of the Board of Aldermen" — six of ten — to convict at the impeachment hearing; the Mayor's tie-breaking authority under Section 79.120 RSMo does not apply to this fixed-majority threshold, as a vote short of six is a failed vote rather than a tie to be broken.

08/12/2026

SPECIAL COUNSEL'S DUAL ROLE AS PRESENTER AND PROSECUTOR

The February 17, 2026 meeting packet lists "Nathan F. Garrett, Special Counsel" as the Point of Contact for Bill No. 6707-26, the ordinance to remove Thomas from office.

At the February 17, 2026 meeting, Garrett — not an alderman — personally presented the ordinance and articles of impeachment to the Board, informed the Board it would be brought back for a second reading, and subsequently requested and was granted a 30-day postponement.

At the April 14, 2026 meeting, Garrett again presented the matter, described the ordinance's function as creating a "case in controversy" to enable a subpoena to the Department of Revenue, and requested the Board's vote to authorize both the ordinance and his own subpoena authority (jointly with the Mayor).

Ordinances in Missouri municipalities are, as a matter of standard legislative procedure, introduced by aldermen — not by outside counsel retained by the City Administrator.

The April 14, 2026 ordinance separately authorized Mayor McDonough to select Garrett as legal advisor to the Mayor in his role as presiding hearing officer — meaning the same attorney presenting the case against Thomas was also positioned to advise the official who would preside over the hearing on that case.

Garrett stated at the April 14, 2026 meeting that the current posture is "potentially a suspension" of Thomas's position — a characterization with no basis in Chapter 79 RSMo, Section 115.306 RSMo, or any Raytown ordinance, none of which recognize an intermediate "suspended" status between seated alderman and lawfully removed alderman

08/12/2026

EXCLUSION FROM THE JANUARY 20, 2026 CLOSED SESSION

On January 20, 2026, the Board of Aldermen convened a Closed Session under the stated authority of Section 610.021(1) RSMo (legal actions, causes of action, or litigation involving a public governmental body, and confidential attorney communications).

Per the City's own February 17, 2026 meeting packet, the Draft Ordinance and Articles of Impeachment against Thomas were given to the Board of Aldermen to review during that January 20, 2026 Closed Session.

The official minutes of the January 20, 2026 meeting list eight aldermen present and one absent (Garza); Thomas does not appear anywhere on that roll call, as present or absent.

Section 610.021(1)'s exception for "legal actions, causes of action or litigation... and confidential or privileged communications between a public governmental body... and its attorneys" is, on its face, designed to protect a governmental body's position in matters adverse to outside parties — not to permit a sitting Board member's own colleagues to review the case against her, and draft the instrument to remove her, outside her presence.

The City's own counsel later admitted on April 14, 2026 that Thomas had "been a member the entire time" — meaning that as of the January 20, 2026 closed session, by the City's own later account, she was a sitting Board member excluded from a session reviewing the case for her own removal.

08/11/2026

Throughout the year 2025, it was once openly stated that the JCBOE sent information to the City of Raytown to take action and remove me from elected office as the Alderman for Ward 3.

With some serious concern, I immediately contacted the JCBOE for authority and clarification because I couldn't find any Missouri statutes that gives them authority to instruct a city to remove an elected official.
I was also concerned because this statement was coming from some of the Board of Alderman members. That statement revealed that some members of the BOA were unaware of how the government operates or has a bias understanding of how it works and for whom it works.
And this is their response...

Without hesitation or silence, this is the response that I received.

👇🏾👇🏾👇🏾👇🏾👇🏾👇🏾

Well...I guess from their response it appears that they are cleared from involvement of the illegal activity.😉

08/11/2026

SELECTIVE ENFORCEMENT, UNEQUAL TREATMENT, AND POTENTIAL POLITICAL MOTIVATION

From a legal and procedural standpoint, the selective enforcement of statutory provisions against one elected official, while comparable conduct by another elected official is not subjected to the same scrutiny or consequences, raises serious concerns regarding equal treatment, selective enforcement, pretext, and the proper exercise of municipal authority.

In this matter, the (Mayor) City has undertaken proceedings against Latrice Thomas based upon alleged violations and has relied upon Section 79.240, RSMo., as part of the asserted basis for removal. However, if evidence demonstrates that another elected official, including the Mayor, engaged in conduct that is materially similar or comparable and was not subjected to the same investigation, hearing, impeachment process, or removal proceedings, the disparity in treatment warrants examination.

The issue is not whether the City possesses the authority to enforce its laws. The issue is whether that authority is being exercised consistently, impartially, and in accordance with the law.

🫡 SALUTE to Alderman T**h, Ward 2 for sharing her thoughts boldly in a BOA public meeting on July 21, 2026.
✨️I encourage you to watch the meeting in its entirety.✨️