Justia Missouri Supreme Court Opinion Summaries

The Supreme Court affirmed the circuit court judgments denying two employers’ requests for permanent writs of mandamus against the Missouri Commission on Human Rights (MCHR). The circuit court rejected Employers’ arguments that the MCHR was required to first determine whether Employers’ employees’ complaints of discrimination were timely filed with the MCHR before the MCHR had authority to issue the employees a right-to-sue letter. The Supreme Court held (1) Mo. Rev. Stat. 213.111.1 requires the MCHR to issue a right-to-sue letter and terminate all proceedings related to a complaint if 180 days have elapsed and the employee has made written request for a right-to-sue letter; and (2) because that is what occurred in both of these cases, the MCHR was required to issue the right-to-sue letters, and the circuit court properly refused to issue writs directing the MCHR to perform an act the MHRA prohibits. View "State ex rel. Tivol Plaza, Inc. v. Missouri Commission on Human Rights" on Justia Law

Two former employees of the Missouri Department of Insurance (collectively, Employees) filed a petition in Jackson County circuit court requesting a writ of mandamus directing the Department and its director (collectively, Respondents) to pay Employees for lost wages and pensions. After an inquiry by the circuit court’s administrator, Employees instructed that the case be handled as a regular Jackson County case and not as a writ. In compliance with Employees’ instructions, summonses for a civil case were issued by the circuit court and served. The parties eventually filed competing motions for summary judgment. More than three years after the initial filing, the circuit court sustained Respondents’ motion for summary judgment, concluding that Employees failed to establish a basis for mandamus. The Supreme Court dismissed Employees’ appeal, holding that because the circuit court never granted a preliminary writ, the denial of mandamus relief was not subject to appeal. View "Bartlett v. Missouri Department of Insurance" on Justia Law

Bishop & Associates, LLC (B&A) filed an action against Ameren Corp. and others (collectively, Ameren and the supervisors) alleging wrongful discharge in violation of public policy and other claims after Ameren terminated its relationship with B&A. The circuit court entered summary judgment for Ameren and the supervisors on all counts. The Supreme Court affirmed, holding (1) Missouri does not recognize a cause of action for wrongful discharge in violation of public policy for independent contractors; (2) the circuit court did not err in granting summary judgment to the defendants on B&A’s claim of breach of the implied covenant of good faith and fair dealing; (3) Missouri case law does not support breach of contract claim for wrongful termination in violation of public policy; and (4) the circuit court did not err in entering summary judgment on B&A’s tortious interference with a business expectancy claim. View "Bishop & Associates, LLC v. Ameren Corp." on Justia Law

The circuit court awarded Plaintiff $500,000 in damages on his claim against the Kansas City School District for wrongful discharge in violation of public policy. The Supreme Court remitted the award to $403,189 and affirmed the judgment of the circuit court in all other respects, holding that the circuit court (1) did not err in overruling the district’s motion for judgment notwithstanding the verdict; (2) did not err in overruling the district’s motion for new trial based on alleged errors in a jury instruction; but (3) erred in overruling the district’s motion for remittitur because the award exceeded that which is allowed by law. View "Newsome v. Kansas City, Missouri School District" on Justia Law

Respondent, a former police officer with the Saint Louis Metropolitan Police Department (SLMPD), filed a complaint against SLMPD, the Saint Louis Board of Police Commissioners (Board), and related individuals, alleging that Defendants retaliated against her in violation of the Missouri Human Rights Act. The circuit court entered judgment in favor of Respondent. The Supreme Court reversed, holding that the circuit court erred in tendering Instruction No. 8 to the jury because the instruction confused the facts regarding Respondent’s disability claim and misdirected the jury about the Board’s legal authority to refuse Respondent’s disability pension application, and Defendants were prejudiced by the instruction’s submission. Remanded. View "Ross-Paige v. Saint Louis Metro. Police Dep’t" on Justia Law

Appellant, who was employed by the Missouri Department of Corrections as a corrections officer, was involved in a workplace accident. Appellant filed a claim for workers’ compensation seeking reimbursement from the Department for medical expenses. The Labor and Industrial Relations Commission denied Appellant’s claim for workers’ compensation benefits, finding that Appellant was involved in a workplace accident but that Appellant did not prove that the accident was the “prevailing factor” causing his medical condition. The Supreme Court reversed, holding that Appellant proved by substantial and competent evidence that his workplace accident was the prevailing factor causing his medical condition. View "Malam v. State, Dep’t of Corr." on Justia Law

Peggy Stevens McGraw and Samuel C. Jones filed suit alleging the State erroneously implemented the 2010 compensation schedule adopted by the Missouri Citizens' Commission on Compensation for Elected Officials pursuant to Mo. Const. art. XIII, sec. 3. They claimed that as a result of this error they were underpaid for their services, which also resulted in underpaid retirement benefits. The trial court dismissed with prejudice all counts raised by the appellants, and the Supreme Court affirmed that dismissal. The Supreme Court found the trial court correctly concluding that appellants' claims were based on an interpretation of art. XIII, sec. 3 that was incorrect as a matter of law and that retirement benefits were properly calculated. View "McGraw v. Missouri" on Justia Law

Appellant was a federal employee with a health insurance plan governed by the Federal Employee Health Benefits Act (FEHBA). Appellant filed suit against Group Health Plan, Inc. and ACS Recovery Services, Inc. (collectively, Respondents) after Respondents enforced a subrogation lien against the proceeds from Appellant’s settlement of a personal injury claim. The trial court entered summary judgment for Respondents, concluding that FEHBA preempts Missouri anti-subrogation claims. The Supreme Court reversed, holding that 5 U.S.C. 8902(m)(1) of FEHBA does not preempt Missouri law prohibiting subrogation of personal injury claims. The United States Supreme Court vacated the Court’s decision and remanded for a determination as to whether a new regulation promulgated by the Office of Personnel Management (OPM) established the FEHBA preempts Missouri’s anti-subrogation law. The Supreme Court held that the OPM regulation did not establish that FEHBA preempts Missouri law prohibiting the subrogation of personal injury claims. Remanded. View "Nevils v. Group Health Plan, Inc." on Justia Law

Employee filed a claim for workers’ compensation benefits against Employer and the Second Injury Fund for an ankle injury. An Administrative Law Judge (ALJ) determined that Employee was entitled to temporary total disability (TTD) benefits but was not entitled to permanent total disability (PTD) benefits. Employee filed an application for review. The Commission modified the ALJ’s award, determining that Employee was entitled to an additional award of TTD benefits for past medical expenses. Both Employee and Employer appealed. The Supreme Court affirmed, holding that the Commission did not err in (1) denying Employee PTD benefits; and (2) modifying the ALJ’s decision and awarding Employee an additional period of TTD benefits. View "Greer v. Sysco Food Servs." on Justia Law

Plaintiff was sixty-one years old when his employment with the Kansas City Chiefs was terminated. Plaintiff was replaced by a younger worker. Plaintiff filed a petition in the circuit court alleging a single act of age discrimination on the day of his termination. In pretrial proceedings, the trial court denied Plaintiff’s request to have testimony presented to the jury from numerous nonparty former employees over age forty who were either fired or pressured to resign and their job duties were assumed by younger replacements. The jury ultimately returned a verdict in favor of the Chiefs. The Supreme Court vacated the judgment, holding that the trial court (1) misapplied the legal standard for admission of evidence by so-called “me too” witnesses and abused its discretion in excluding “me too” evidence offered by the former employees; and (2) erred in excluding evidence concerning a discriminatory age-related statement allegedly made by a Chiefs executive and in quashing a deposition order issued to the Chiefs’ chairman and chief executive officer. Remanded. View "Cox v. Kansas City Chiefs Football Club, Inc." on Justia Law