Justia Missouri Supreme Court Opinion Summaries
Articles Posted in Labor & Employment Law
McGraw v. Missouri
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
Posted in:
Constitutional Law, Labor & Employment Law
Nevils v. Group Health Plan, Inc.
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
Posted in:
Injury Law, Labor & Employment Law
Greer v. Sysco Food Servs.
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
Cox v. Kansas City Chiefs Football Club, Inc.
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
State ex rel. ISP Minerals, Inc. v. Labor & Indus. Relations Comm’n
Employee filed a claim for workers’ compensation benefits arising out of a work-related pulmonary condition. Employer and Employee entered into a settlement that expressly left “future related pulmonary med[ical] care open.” An administrative law judge approved the settlement. The dispute in this case centered on Employer’s refusal to pay for certain inhaler medicines prescribed to Employee. Employee filed a request for a hearing before the Labor and Industrial Relations Commission to determine whether Employer was required to pay for the inhalers. The Commission concluded that it retained jurisdiction to determine Employer’s liability for Employee’s future medical care and ordered the parties to present their evidence in a hearing before the Division of Workers’ Compensation. Thereafter, Employer filed a petition for a writ of prohibition and, alternatively, mandamus, asserting that the parties’ settlement divested the Commission of jurisdiction over the issue of Employer’s liability for Employee’s future medical care. The Supreme Court quashed the preliminary writ, holding that the Commission was not divested of jurisdiction to determine the extent of a claimant’s entitlement to workers’ compensation benefits pursuant to a settlement that expressly leaves the issue of future medical care “open” and indeterminate. View "State ex rel. ISP Minerals, Inc. v. Labor & Indus. Relations Comm’n" on Justia Law
Gateway Taxi Mgmt. v. Div. of Employment Sec.
Geteway Taxi Management, d/b/a Laclede Cab Company (Laclede), operated a taxi service in the St. Louis metropolitan area. The Division of Employment Security determined that Laclede was liable for unemployment tax because its taxi drivers performed services for “wages” in the “employment” of Laclede. under Mo. Rev. Stat. 288.034.5. The appeals tribunal reversed. The Labor and Industrial Relations Commission (LIRC) reversed, finding that the taxi drivers were “employees” of Laclede under Mo. Rev. Stat. 288.034.5. The Supreme Court affirmed, holding that there was competent and substantial evidence on the record to support LIRC’s decision that Laclede’s drivers were employees of Laclede. View "Gateway Taxi Mgmt. v. Div. of Employment Sec." on Justia Law
State ex rel. Hewitt v. Hon. Kerr
Plaintiff, a former employee of the St. Louis Rams Partnership, filed an action claiming age discrimination against the Partnership and three of its affiliates. The Rams moved to compel arbitration, citing an arbitration provision of Plaintiff’s employment contract. The trial court granted the motion and ordered that the court action be stayed pending arbitration. Plaintiff petitioned for a writ of mandamus preventing the trial court from compelling arbitration of this dispute. Four judges of the Supreme Court issued a permanent writ of mandamus directing the trial court to vacate its order granting the motion to compel arbitration and to issue an order to compel arbitration whereby the trial court appoints a neutral arbitrator and implies the specific terms of arbitration from applicable statutes in Missouri’s uniform arbitration act, holding (1) the terms of Plaintiff’s employment contract designating the commissioner of the National Football League (NFL) as the sole arbitrator with unfettered discretion to establish the rules for arbitration are unconscionable and, therefore, unenforceable; and (2) Missouri’s uniform arbitration act provides a mechanism to imply the terms missing from the arbitration agreement and provides the rules for appointing an arbitrator to replace the NFL commissioner. View "State ex rel. Hewitt v. Hon. Kerr" on Justia Law
Posted in:
Arbitration & Mediation, Labor & Employment Law
Baker v. Bristol Care, Inc.
When Respondent was promoted from her position was an hourly employee to a salaried managerial position at one of Appellants’ long-term care facilities, the parties signed an employment agreement and arbitration agreement. Appellants later terminated Respondent from her position. Respondent filed a class action lawsuit against Appellants seeking compensation for allegedly unpaid overtime hours. Appellants filed a motion to compel arbitration, but the circuit court overruled the motion. The Supreme Court affirmed, holding that Respondent’s continued at-will employment and Appellants’ promise to resolve claims through arbitration did not provide valid consideration to support the arbitration agreement. View "Baker v. Bristol Care, Inc." on Justia Law
Tolentino v. Starwood Hotels & Resorts Worldwide, Inc.
Appellant was paid by a staffing company to clean rooms at a hotel. Appellant later filed a class action suit against the staffing company and Respondents, the owner and manager of the hotel, alleging that Respondents and the staffing company were his employers and that Respondents failed to comply with the Missouri Minimum Wage Law (MMWL). The circuit court granted summary judgment in favor of Respondents, concluding that there were genuine issues of material fact regarding whether Respondents were Appellant’s employer, and even if Respondents were Appellant’s employer, they could not be held responsible for the alleged wage deficiency because it was caused by the staffing company’s unforeseeable, illegal wage deductions. The Supreme Court reversed, holding that if Respondents were Appellant’s employer for purposes of MMWL, the staffing company’s illegal wage deductions did not absolve Respondents from their independent statutory duty as Appellant’s employer to pay him a minimum wage. Remanded. View "Tolentino v. Starwood Hotels & Resorts Worldwide, Inc." on Justia Law
Posted in:
Labor & Employment Law
Mickey v. BNSF Ry. Co.
At issue in this case was whether the Railroad Retirement Tax Act (RRTA) requires employers to withhold RRTA taxes on a personal injury plaintiff’s Federal Employers’ Liability Act (FELA) suit. Plaintiff in this case received a judgment on his FELA claim against Burlington Northern Santa Fe Railway Company (BNSF). BNSF tendered less than what it owed on the judgment, claiming that it was required to treat the judgment as if it were for lost wages and therefore subject to RRTA withholding taxes. The trial court concluded that BNSF failed to satisfy the judgment and ordered Safeco Insurance Company, BNSF’s surety, to pay Plaintiff the withheld amount. The Supreme Court affirmed, noting that damages received through a suit or settlement for personal injuries are normally not subject to retirement taxes, and holding that BNSF was incorrect in arguing that the RRTA creates an exception to this law for railroad retirement taxes. View "Mickey v. BNSF Ry. Co." on Justia Law
Posted in:
Injury Law, Labor & Employment Law