This Note argues that the current standard for substantial evidence is both confusing and inconsistent in Missouri case law. In the instant case, the standard for substantial evidence applied by the Missouri Court of Appeals, Southern District, involved weighing the credibility of the evidence when, according to the weight of authority in Missouri case law, the substantial evidence standard is a low one and does not include making determinations of credibility. Substantial evidence would be better defined as any evidence that is more than a mere scintilla that puts a matter in issue
Anthony J. Meyer,
Sound and Fury: Substantial Evidence in State v. Bruner,
82 Mo. L. Rev.
Available at: https://scholarship.law.missouri.edu/mlr/vol82/iss2/11