Justia Missouri Supreme Court Opinion Summaries

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

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

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

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

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

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

Employer terminated Employee for falsifying his doctor’s return-to-work certificate. Employee sought unemployment benefits, but the Division of Employment Security denied the application on the ground that Employee had been fired for misconduct connected with his work. The Labor and Industrial Commission affirmed the denial of unemployment benefits. The Supreme Court affirmed, holding that the Commission did not err in denying benefits, as (1) willfulness is not required for all forms of misconduct; (2) Employee disregarded a standards of behavior that Employer had a right to expect from its employees; and (3) Employee’s misconduct was “connected to” his work. View "Seck v. Div. of Employment Sec." on Justia Law

In 2006, Appellant was injured in the course and scope of his employment when a large metal beam crushed his left foot. Appellant received workers’ compensation benefits for his injury. Appellant subsequently returned to work for Employer on “light duty.” Appellant was on a break to rest his foot when Employer’s owner terminated him. Thereafter, Appellant filed a claim of retaliatory discharge against Employer. A jury entered a verdict in favor of Employer. The Supreme Court reversed, holding (1) to make a submissible case for retaliatory discharge under Mo. Rev. Stat. 287.780, an employee must demonstrate his or her filing of a workers’ compensation claim was a “contributing factor” to the employer’s discrimination or the employee’s discharge; and (2) the trial court erred in instructing the jury that it had to determine Appellant was discharged exclusively in retaliation for filing a workers’ compensation claim. Remanded for a new trial. View "Templemire v. W&M Welding, Inc." on Justia Law

Claimant worked part-time for Design Design from July 2008 until she obtained full-time employment in March 2010. Claimant received $320 in unemployment benefits and $25 in federal stimulus benefits for each of forty-eight weeks from May 2009 to March 2010. After the Labor and Industrial Relations Commission discovered Claimant’s employment with Design Design, the Commission found that Claimant willfully failed to disclose that she was working during the period she was receiving benefits. Therefore, the Commission determined that Claimant must return part of her benefits and pay certain penalties. The Supreme Court largely affirmed, the Commission’s decisions, holding that sufficient competent evidence in the record supported all of the Commission’s actions, except for the amount of one of the penalties. Remanded with instructions to reassess that penalty. View "Coday v. Div. of Employment Sec’y" on Justia Law

Plaintiff filed an action against his employer, BNSF Railway Company, for damages related to an injury he sustained while in the course and scope of his employment. Plaintiff asserted claims for negligence under the Federal Employers’ Liability Act (FELA). The trial court granted judgment in favor of BNSF. Defendant appealed, asserting three claims of error relating to the trial court’s exclusion of certain evidence at trial. The Supreme Court affirmed the judgment in all respects, holding that the trial court did not abuse its discretion in its evidentiary rulings challenged by Plaintiff. View "Lozano v. BNSF Ry. Co." on Justia Law