Justia Missouri Supreme Court Opinion Summaries

Articles Posted in Labor & Employment Law
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The Supreme Court affirmed the judgment of the circuit court in favor of Meyer Electric Company on John Lisle's claim that Meyer Electric violated Mo. Rev. Stat. 287.780 by refusing to hire him because he exercised his chapter 287 rights during his prior employment relationship with the company, holding that there was no error.On appeal, Lisle argued that the circuit court misapplied the provisions of section 287.780 by requiring him to establish that he was an "employee" at the time Meyer Electric discriminated against him for exercising his workers' compensation rights. The Supreme Court disagreed, holding (1) as strictly construed, section 287.780 gives an employee a civil action for damages against his or her employer for discharging or discriminating against the employee while employed because the employee exercised a right established under chapter 287; and (2) because it was an uncontroverted material fact that Lisle was not an employee of Meyer Electric when it refused to hire him, Meyer Electric established its right to judgment, as a matter of law. View "Lisle v. Meyer Electric Co., Inc." on Justia Law

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The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission affirming and adopting the ALJ's final award denying Appellant's claim for benefits from the Second Injury Fund, holding that the Commission did not abuse its discretion in affirming the ALJ's denial of Appellant's post-hearing motions to reopen the record and submit additional evidence.Before the ALJ issued her final award, the Supreme Court decided Cosby v. Treasurer of Missouri, 579 S.W.3d 202 (Mo. banc 2019), which reached a different interpretation of Mo. Rev. Stat. 287.220.3 than that reached by the court of appeals in Gattenby v. Treasurer of Missouri, 516 S.W.3d 859 (Mo. App. 2017). Before the ALJ's final award, Appellant filed a motion to reopen the record for a supplemental hearing based on Cosby. The ALJ overruled the motion and issued her award. The Commission affirmed. The Supreme Court affirmed, holding that the Commission did not abuse its discretion in overruling Appellant's motions to reopen the record and submit additional evidence. View "Weibrecht v. Treasurer of Mo. as Custodian of Second Injury Fund" on Justia Law

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The Supreme Court reversed the judgment of the circuit court entering summary judgment for Employer and dismissing Employee's class action claiming that Employer violated the Missouri Prevailing Wage Act by failing to pay its employees the prevailing wage for work performed on properties in Kansas City, Missouri, holding that a genuine dispute existed, precluding summary judgment.Employee, individually and on behalf of a class of all similarly situated, filed a petition alleging that Employer violated the State's prevailing wage act and minimum wage law. The circuit court sustained Employer's motion for summary judgment as to all claims, and the court of appeals affirmed. The Supreme Court reversed, holding (1) the record supported two plausible but contrary inferences as to whether Employee was employed "on behalf of any public body engaged in the construction of public works" within the meaning of the Prevailing Wage Act; and (2) therefore, a genuine dispute of material fact existed, barring summary judgment. View "Brockington v. New Horizons Enterprises, LLC" on Justia Law

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The Supreme Court reversed the judgment of the circuit court in favor of several unions (Unions) and issuing a permanent injunction enjoining the State from altering existing collective bargaining agreements with the Unions pursuant to Senate Bill No. 1007 and ordering the State to bargain in good faith with the Unions without constraint from SB 1007, holding that the circuit court's judgment erroneously declared and applied the law.SB 1007 removed most state employees from the merit system by designating their employment statuses as at-will. The circuit court determined that SB 1007 did not impact collective bargaining or mandate at-will employment and that SB 1007 violated Mo. Const. art. I, 29 and 13. The Supreme Court reversed, holding (1) SB 1007 mandates at-will employment and restricts the State's ability to agree to terms of employment inconsistent with at-will employment; and (2) SB 1007 does not violate the right to bargain collectively as guaranteed by article I, section 29 of the Missouri Constitution. View "American Federation of State, County & Municipal Employees, AFL-CIO, Council 61 v. State" on Justia Law

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The Supreme Court reversed the judgment of the circuit court issuing a permanent writ of mandamus in favor of Jim Swoboda, holding that the circuit court's decision was erroneous because Swoboda failed to establish that he was entitled to mandamus relief.Swoboda filed a charge of discrimination with the Missouri Commission on Human Rights against his employer and Armstrong Teasdale, LLP (the Law Firm), alleging retaliation, disability, and aiding and abetting as types of discrimination he faced in retaliation for participating in a discrimination case brought by another officer. The Commission determined that it lacked jurisdiction over the matter because there was no employer-employee relationship between Swoboda and the Law Firm. The circuit court issued a writ of mandamus finding that the Commission erred in dismissing the charge without first taking certain steps. The Supreme Court reversed, holding that the issuance of mandamus relief was foreclosed where, rather than seeking to enforce a previously delineated right, Swoboda attempted to adjudicate whether his claim was permissible under applicable statutes. View "State ex rel. Swoboda v. Missouri Commission on Human Rights" on Justia Law

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The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission denying Claimant's claim for permanent total disability (PTD) benefits from the Second Injury Fund, holding that the Commission appropriately found that Claimant was not permanently and totally disabled.Claimant filed an amended workers' compensation claim against Employer, alleging that his primary work-related injuries were "bilateral upper extremities" and asserting a claim against the Fund for PTD benefits due to a prior injury to his bilateral lower extremities. An administrative law judge denied PTD benefits, and the Commission affirmed. The Supreme Court affirmed, holding that Claimant failed to carry his burden of persuasion in demonstrating that he was entitled to PTD benefits. View "March v. Treasurer of Missouri" on Justia Law

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The Supreme Court reversed the judgment of the circuit court dismissing Plaintiff's complaint against Independence School District alleging that he had been fired in retaliation for filing a workers' compensation claim, in violation of Mo. Rev. Stat. 278.780, holding that the general assembly expressly waived whatever immunity the school district might have had.In dismissing Plaintiff's complaint, the circuit court found that the school district enjoyed sovereign immunity from Plaintiff's workers' compensation retaliation claim. On appeal, Plaintiff argued that workers' compensation claims are authorized against the school district because the legislature included state and political subdivisions such as school districts as employers for purposes of the Workers' Compensation Law. The Supreme Court agreed and reversed, holding that, considered together, sections 278.780 and Mo. Rev. Stat. 287.030 reflect an express showing of legislative intent to waive the school district's sovereign immunity for Plaintiff's workers' compensation retaliation claim. View "Poke v. Independence School District" on Justia Law

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The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission reversing the administrative law judge's (ALJ) award of permanent and total disability (PTD) benefits against the Second Injury Fund, holding that the Commission's findings were supported by substantial and competent evidence.Christopher Klecka suffered a compensable work-related injury to his left shoulder. After settling the primary claim with his employer Klecka brought a claim against the Fund, alleging that his primary injury combined with his prior injuries rendered him permanently and totally disabled (PTD). An ALJ issued an award against the fund for PTD benefits. The Commission reversed. The Supreme Court affirmed, holding that Klecka failed to establish that his primary injury and sole qualifying preexisting disability entitled him to PTD benefits from the Fund under Mo. Rev. Stat. 287.220.3. View "Klecka v. Treasurer of Missouri" on Justia Law

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The Supreme Court dismissed this appeal from the decision of the Labor and Industrial Relations Commission (Commission) reversing the administrative law judge's award and denying Claimant permanent total disability benefits, holding that Claimant's brief preserved nothing for appellate review because it failed to comply with the mandatory and straightforward rules governing the contents of an appellant's briefs.After the Commission denied Claimant's claim, Claimant appealed. The Supreme Court dismissed the appeal, holding that each of Claimant's points on appeal was defective because each point relied on wholly failed to follow the simple template provided in Rule 84.04. View "Lexow v. Boeing Co." on Justia Law

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The Supreme Court reversed the circuit court's judgment in favor of Danny Brock on his negligence claim against Mark Edwards, holding that the circuit court erred in overruling the motions for directed verdict and judgment notwithstanding the verdict (JNOV) filed by Peter Dunne, defendant ad litem for Edwards.Brock was injured in a work-related accident involving co-worker Edwards. Brock filed a petition alleging a negligence claim against Edwards. Edwards died before trial, and Dunne was substituted as defendant ad litem. The jury returned a verdict in Brock's favor, and the circuit court entered judgment for $873,000 in Brock's favor. The Supreme Court reversed, holding that the circuit court erred in overruling Dunne's motions for directed verdict and JNOV because Edwards was immune from liability pursuant to Mo. Rev. Stat. 287.120.1 and Brock failed to make a submissible case of common law negligence. View "Brock v. Dunne" on Justia Law