Justia Missouri Supreme Court Opinion Summaries

The Supreme Court made permanent preliminary writs of prohibition sought by Relators to prevent the circuit court from taking any action other than vacating its orders overruling their respective motions to dismiss on the grounds that Plaintiff’s Missouri Human Rights Act (MHRA) claims against them for discrimination and retaliation were time barred.After Relators each filed a motion to dismiss as time barred Alicia Mulvey’s MHRA claims for discrimination and retaliation, Mulvey filed a motion for leave to amend her petition to include common law claims of negligence and wrongful discharge. The circuit court overruled Relators’ motions to dismiss and sustained Mulvey’s motion for leave to amend. The Supreme Court held that the circuit court exceeded its authority when it overruled Relators’ motions to dismiss for failure to state a claim and abused its discretion when it sustained Mulvey’s motion for leave to amend her petition because Mulvey failed to file her MHRA claim within the ninety-day statutory period and her common law claims of negligence and wrongful discharge were fully encompassed and comprehended by the MHRA. View "State ex rel. Church & Dwight Co. v. Honorable William B. Collins" on Justia Law

Because Plaintiffs in these two personal injury suits failed to allege a breach of a duty unrelated to employment or a breach of workplace safety that was so unforeseeable to the employer as to take it outside the employer’s nondelegable duty to provide a reasonably safe workplace, the trial court properly granted summary judgment in favor of Plaintiff’s co-employees (Defendants).Plaintiffs in both cases were injured on the job. Plaintiffs sued Defendants for common law negligence, arguing that Defendants breached a duty separate and distinct from their employers’ duty to provide a safe workplace. In each case, the trial court granted summary judgment for Defendants. The Supreme Court affirmed, holding that summary judgment was properly granted under Parr v. Breeden, 489 S.W.3d 774, 778 (Mo. banc 2016) and Peters v. Wady Industries, Inc., 489 S.W.3d 784, 789-90 (Mo. banc 2016). View "Conner v. Ogletree" on Justia Law

In this personal injury suit, the trial court properly granted summary judgment in favor of Defendant under Parr v. Breeden, 489 S.W.3d 774, 778 (Mo. banc 2016) and Peters v. Wady Industries, Inc., 489 S.W.3d 784, 789-90 (Mo. banc 2016).Matthew Fogerty brought this action against Larry Meyer, his co-employee, seeking damages for injuries he sustained while the parties were working together. After the accident, Fogerty filed and settled a workers’ compensation claim for his injuries. Fogerty then filed this personal injury lawsuit against Meyer. Meyer filed a motion for summary judgment, arguing that he was entitled to judgment as a matter of law because Fogerty failed to show that Meyer breached a duty separate and distinct from the employer’s nondelegable duty to provide a safe workplace. The circuit court agreed. The Supreme Court affirmed, holding that Meyer’s negligence was a breach of the employer’s nondelegable duty to provide a safe workplace, not a breach of a duty “separate and distinct” from the employer’s duty. View "Fogerty v. Armstrong" on Justia Law

The Supreme Court affirmed the judgment of the trial court concluding that Plaintiff’s wrongful death action was barred by the exclusivity provision in Missouri’s workers’ compensation statutes, Mo. Rev. Stat. 287.120.Edward McComb died while driving a vehicle for his employer. Plaintiff, McComb's widow, brought this suit against McComb’s supervisory co-employees (collectively, Defendants). The trial court granted summary judgment for Defendants. On appeal, Plaintiff argued that whether McComb’s death was attributable to his employer’s nondelegable duty to provide a safe workplace was a question of fact for a jury to decide, thus precluding summary judgment. The Supreme Court affirmed, holding that Plaintiff failed to establish that Defendants owed McComb a duty separate and distinct from his employer’s nondelegable duty to provide a safe workplace, and therefore, summary judgment was properly granted under Parr v. Breeden, 489 S.W.3d 774, 778 (Mo. banc 2016) and Peters v. Wady Industries, Inc., 489 S.W.3d 784, 789-90 (Mo. banc 2016). View "McComb v. Norfus" on Justia Law

The Supreme Court affirmed the judgment of the circuit court in favor of Plaintiff on her claim of negligence alleging that Defendant, her employer, breached its duty to protect her from the criminal act of a third person on its premises. On appeal, Defendant argued that the circuit court erred in submitting a verdict director to the jury that was not supported by substantial evidence and erred in allowing Plaintiff to make arguments to the jury that misstated the law as instructed in the verdict director. The Supreme Court held (1) the allegation of error made in Defendant’s first point on appeal was not properly preserved; and (2) Defendant’s remaining arguments on appeal were unavailing. View "Wieland v. Owner-Operator Services, Inc." on Justia Law

The Supreme Court affirmed the judgment of the circuit court in favor of Plaintiff on her claim of negligence alleging that Defendant, her employer, breached its duty to protect her from the criminal act of a third person on its premises. On appeal, Defendant argued that the circuit court erred in submitting a verdict director to the jury that was not supported by substantial evidence and erred in allowing Plaintiff to make arguments to the jury that misstated the law as instructed in the verdict director. The Supreme Court held (1) the allegation of error made in Defendant’s first point on appeal was not properly preserved; and (2) Defendant’s remaining arguments on appeal were unavailing. View "Wieland v. Owner-Operator Services, Inc." on Justia Law

The Supreme Court granted mandamus relief to Relator, who sought to resign, revoke, or withdraw the circuit court’s medical authorization order authorizing the release of the decedent’s medical records, holding that the medical authorization order in this case was prohibited by this court’s precedent.Relator filed a wrongful death action against Defendants after his brother, the decedent, died allegedly from metastatic colon cancer. During discovery, Defendants sought an order from the circuit court authorizing the release of the decedent’s medical records. The circuit court signed an order authorizing the release of medical records. Relator then petitioned for this writ to prohibit the use of the decedent’s unlimited medical records. The Supreme Court granted a writ of prohibition, holding that the medical authorization was prohibited because there was no case-by-case review of the medical authorization designed to tailor the requests to the pleadings. View "State ex rel. Fennewald v. Honorable Patricia S. Joyce" on Justia Law

The Supreme Court affirmed the judgment of the circuit court awarding Maddison Schmidt $15 million in compensatory damages and $23 million in punitive damages for her personal injury claim. The court held that the circuit court did not err in overruling Abbott Laboratories, Inc.’s (1) pretrial motion to transfer venue, (2) pretrial motion to sever Schmidt’s claim from other plaintiffs’ claims, (3) motions for directed verdict and judgment notwithstanding the verdict on Schmidt’s failure-to-warn claim, and (4) motions for directed verdict and judgment notwithstanding the verdict on Schmidt’s demand for punitive damages. View "Barron v. Abbott Laboratories, Inc." on Justia Law

The trial court did not abuse its discretion by allowing prospective juror 24 to serve on the jury in this medical negligence case.Following a jury trial, the trial court entered judgment in favor of defendant hospitals. Plaintiffs appealed, arguing that the trial court erred by failing to strike for cause juror 24 because she expressed a disqualifying bias in favor of Defendants. The Supreme Court disagreed, holding that the trial court did not abuse its discretion by finding, without additional questioning, that prospective juror 24 was not disqualified because she was successfully rehabilitated when the entire voir dire was considered, including her later statement that she could follow the trial court’s instructions. View "Thomas v. Mercy Hospitals East Communities" 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