DECISION SUMMARY: County's motion to file amended pleading in remanded 2003 case is denied as untimely. Issue of payment of deputy juvenile officer's salary from 2003 is moot. In the event the commission has the authority to review Hancock violations, the circuit court's order to pay the deputy juvenile officer's salary does not violate Hancock because the county voluntarily joined in the initial grant application for the officer and because his employment is an ongoing operation and not a new activity. Attorney's fees in both 2003 and 2004 are reasonable. The maintenance of effort language in section 211.393.6, RSMo, is a minimum level of funding required of each affected county and can be exceeded by the county on its own motion but not by the order of the circuit court. To allow the court to order the county to exceed maintenance of effort would render the statute meaningless. Finally, irrespective of maintenance of effort, the payment of the deputy juvenile officer's salary also is factually unreasonable in light of the difficult budget circumstances of the county as a whole.

DISSENT: Maintenance of effort statute is not a per se limitation that can be exceeded only at the county's option but rather is a minimum level of funding that informs the commission's determinations of reasonableness in light of the totality of state law. In this case, reasonableness must be determined in light of section 211.011, RSMo, which instructs the juvenile code to be enforced for the best interests of the child, and section 50.640, RSMo, which instructs this commission to resolve all disputes in light of factual reasonableness, as well as the constitutional duty to fund court operations at a reasonable level. Given the workload of the deputy juvenile officer in question and the importance of his work, which neither party disputes, funding the officer's salary is reasonable even if it exceeds the maintenance of effort calculation.

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