Justia Missouri Supreme Court Opinion Summaries

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

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

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

The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission finding that Defendant was not entitled to an award of workers' compensation benefits because his injury did not arise out of and in the course of his employment, holding that there was no error.Defendant, a field service specialist for DISH Network, Inc,. was an a car accident after he choked on a sandwich and blacked out while traveling to his first appointment. Defendant sought workers' compensation benefits. The ALJ awarded benefits, but the Commission denied compensation because Defendant failed to prove his injury arose out of and in the course of his employment. The Supreme Court affirmed, holding that Defendant failed to establish that his injury arose out of and in the course of his employment. View "Boothe v. DISH Network, Inc." on Justia Law

The Supreme Court vacated the judgment of the circuit court reversing the decision of the Board of Education of the Jefferson City Public School District to terminate Tammy Ferry's contract with the District, holding that the Board had the authority to terminate the contract.The Board decided to terminate Ferry's contract after she transferred confidential student information from the District's Google for Education account to her personal Google account. The circuit court vacated the Board's decision, finding that Ferry had not "disclosed" confidential student information, as that term is defined in the Family Educational Rights and Privacy Act of 1974 (FERA), 20 U.S.C. 1232g. The Supreme Court vacated the circuit court's judgment, holding (1) the Board's findings that Ferry violated the Board's policies and procedure and did so willfully were supported by competent and substantial evidence; and (2) the Teacher Tenure Act authorized the Board to terminate Ferry's indefinite contract with the District. View "Ferry v. Board of Education of Jefferson City Public School District" on Justia Law

The Supreme Court affirmed in part and vacated in part the judgment of the circuit court awarding a class of Missouri corrections officers $113 million plus post-judgment interest for breach of contract, holding that the circuit court's determination that all preshift and postshift activities are compensable was erroneous.On appeal, the Missouri Department of Corrections (MDOC) argued that the circuit court erroneously determined that MDOC was liable on the corrections officers' breach of contract claims for time spent performing all preshift and postshift activities. The Supreme Court held (1) the circuit court erred in determining that all corrections officers' preshift and postshift activities were compensable principal activities that must be compensated; (2) because the award of damages and the court's declaratory and injunctive relief were based on the erroneous finding of liability, those rulings were erroneous; and (3) the circuit court correctly determined that MDOC must compensate corrections officers for time spent retrieving keys and radios and time spent monitoring and supervising offenders while not on post. View "Hootselle v. Missouri Department of Corrections" on Justia Law

The Supreme Court vacated the Labor and Industrial Relations Commission awarding permanent total disability (PTD) benefits to Jonathan Parker under Mo. Rev. Stat. 287.220.2, holding that the Labor and Industrial Relations Commission erred in applying subsection 2 of section 287.220 rather than subsection 3 of the statute, and remand was required.Before the Supreme Court, the Second Injury Fund argued that Parker should be denied benefits under subsection 3. Parker, in turn, argued that the Supreme Court should award him benefits under subsection 3. The Supreme Court vacated the Commission's decision, holding (1) under Mo. Const. art. V, 18, the Supreme Court is permitted to review only the decisions and findings of the Commission, not to make such decisions in the first place; and (2) therefore, remand to the Commission was required to determine whether Parker was entitled to benefits under subsection 3. View "Treasurer of State as Custodian of the Second Injury Fund v. Parker" on Justia Law

The Supreme Court made permanent a preliminary writ of prohibition directing the circuit court to enter summary judgment in favor of Brian Henderson and Beutler, Inc., d/b/a George J. Shaw Construction Co. (Shaw), for injuries Joshua McArthur sustained while operating a dump truck on a construction site, holding that both Henderson and Shaw were immune from suit.In their motion for summary judgment, Henderson and Shaw asserted immunity from suit under the workers' compensation exclusivity doctrine. The circuit court overruled the motion, finding that the exception from workers' compensation exclusivity found in Mo. Rev. Stat. 287.040.4 applied. The Supreme Court affirmed, holding that the circuit court's findings regarding the application of section 287.040.4 were erroneous. View "State ex rel. Beutler, Inc. v. Honorable Sandra C. Midkiff" on Justia Law

In this disability discrimination action, the Supreme Court reversed the award of litigation expenses but affirmed in all other respects the circuit court's judgment in favor of Plaintiff, holding that no statute allows a circuit court to award as litigation expenses the expenses incurred by counsel for the prevailing party in a Missouri Human Rights Act (MHRA) case.Plaintiff sued the City of Kansas City for disability discrimination and retaliation under the MHRA. The jury returned a verdict in Plaintiff's favor, awarding him actual and punitive damages. The circuit court entered judgment in conformity with the verdict. Upon Plaintiff's motion, the circuit court amended the judgment to award attorney fees and litigation expenses. The Supreme Court affirmed in part and reversed in part, holding (1) the City's argument that the circuit court erred in admitting evidence and argument of Plaintiff's workers' compensation permanent partial disability rating was not preserved for appellate review; and (2) the circuit court erred in awarding Plaintiff litigation expenses because no statute authorizes an award of litigation expenses in an MHRA case. View "Wilson v. City of Kansas City" on Justia Law

The Supreme Court affirmed the judgment of the circuit court on a jury verdict for Plaintiff on her claim that, as directors of the closely held Perma-Jack Company, Defendants breached their fiduciary duty to Plaintiff as a shareholder, holding that the circuit court did not abuse its discretion.Specifically, the Supreme Court held (1) with respect to Plaintiff's breach of fiduciary claim, because Plaintiff did not sue Perma-Jack itself for lost wages or reinstatement, Plaintiff's claim was not actually one for wrongful termination, as Defendants argued; (2) the circuit court did not err in finding that Defendants engaged in shareholder oppression and ordering Defendants to buy Plaintiff's Perma-Jack shares; and (3) the circuit court did not abuse its discretion in determining the fair value of Plaintiff's shares and in denying Plaintiff prejudgment interest and attorney's fees. View "Robinson v. Langenbach" on Justia Law