Justia Labor & Employment Law Opinion SummariesArticles Posted in Supreme Court of Missouri
Schoen v. Mid-Missouri Mental Health Center
The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission denying Employee's workers' compensation benefits on the grounds that she failed to prove her work injury was the prevailing or primary factor causing any permanent disability and denying Employee's claim against the Second Injury Fund as moot, holding that the Commission did not err. Employee was exposed to cypermethrin, an insecticide, while working for Employer. When Employee was at the doctor's office for testing, another patient's dog got loose and tripped Employee. Employee fell and allegedly sustained permanent injuries to her knees, lower back, hip and neck. Employee filed a claim for workers' compensation asserting that, in addition to cypermethrin exposure, she sustained injuries from being tripped while walking out of the doctor's office. An ALJ awarded Employee benefits. The Commission reversed, concluding that Employee failed to meet her burden of proving her exposure to cypermethrin was the prevailing or primary factor in causing any alleged injury from being tripped accidentally. The Supreme Court affirmed, holding (1) Employee was not entitled to workers' compensation for any injury sustained from her accidental tripping; and (2) because Employee's accidental tripping did not arise out of and in the course of her employment, the Fund was not implicated. View "Schoen v. Mid-Missouri Mental Health Center" on Justia Law
Karney v. Department of Labor & Industrial Relations
The Supreme Court affirmed the judgment of the circuit court to the extent it enjoined the State from prohibiting unobtrusive picketing about matters of public concern in negotiations for a new labor agreement with the CWA Local 6360, holding that Mo. Rev. Stat. 105.585(2)'s prohibition against "picketing of any kind" is unconstitutional, but severance of the phrase renders the provision constitutional. The circuit court enjoined the State from enforcing or implementing section 105.585(2)'s mandated prohibition against "picketing of any kind" in negotiating a collective bargaining agreement with certain public employees. In so holding, the circuit court declared section 105.585(2) unconstitutional under both the state and federal constitutions as it relates to picketing. The Supreme Court affirmed, holding (1) section 105.585(2) violates Mo. Const. art. I, 8; (2) severance of the portion of the statute prohibiting "picketing of any kind" is applicable and appropriate; and (3) permanent injunction was the appropriate remedy in this case. View "Karney v. Department of Labor & Industrial Relations" on Justia Law
Annayeva v. SAB of the TSD of the City of St. Louis
The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission denying Appellant's claim for workers' compensation benefits for injuries she suffered when she fell while entering her workplace, holding that Appellant failed to prove that her injury arose out of and in the course of her employment. An administrative law judge denied Appellant any workers' compensation benefits, concluding that Appellant did not meet her burden of showing that her fall was the prevailing factor causing the conditions of which she complained. The Commission affirmed, holding that Appellant failed to establish that her injury arose out of her employment. The Supreme Court affirmed, holding that Appellant's claim was noncompensable because she failed to prove her injury arose out of and in the course of her employment because the hazard or risk involved was one Appellant was equally exposed to in her regular, nonemployment life. View "Annayeva v. SAB of the TSD of the City of St. Louis" on Justia Law
Hegger v. Valley Farm Dairy Co.
The Supreme Court affirmed the decision of the labor and industrial relations commission denying Claimants' claim for enhanced mesothelioma benefits under Mo. Rev. Stat. 287.200.4(3)(a), holding that because the deceased employee's employer (Employer) did not "elect to accept mesothelioma liability," Claimants were not entitled to the enhanced benefit. The decedent died from mesothelioma cause by toxic exposure to asbestos during his employment with Employer. Prior to his death, Claimants filed a claim for workers' compensation benefits and specifically sought enhanced benefits under subdivision 287.200.4(3)(a). An administrative law judge denied the claim. The commission affirmed the denial of the enhanced benefit, concluding that an employer that ceased operations sixteen years before section 287.200.4(3)(a) took effect could not have elected to accept enhanced liability under that section. The Supreme Court affirmed, holding that Claimants were not entitled to the enhanced benefit because Employer did not affirmatively elect to accept liability for the enhanced benefit as required under statute. View "Hegger v. Valley Farm Dairy Co." on Justia Law
Theroff v. Dollar Tree Stores, Inc.
The Supreme Court affirmed the order of the circuit court overruling Dollar Tree's motion to compel arbitration and stay proceedings on a former employee's claim of disability discrimination, holding that the order was supported by substantial evidence, was not against the weight of the evidence, and correctly applied the law. After Plaintiff, Dollar Tree's former employee, brought this complaint Dollar Tree filed a motion to compel arbitration and stay proceedings under an arbitration agreement in the employment contract. The parties, however, disputed whether there was assent to the arbitration agreement. The circuit court denied the motion to compel arbitration after hearing testimony but did not make any findings. The Supreme Court affirmed, holding that there was no clear and unmistakable evidence of the existence of assent to a delegation provision, and therefore, the circuit court could not delegate the matter to an arbitrator whose existence depended upon the agreement. View "Theroff v. Dollar Tree Stores, Inc." on Justia Law
Lin v. Ellis
In this suit alleging retaliation pursuant to section 213.070 of the Missouri Human Rights Act (MHRA) the Supreme Court reversed the judgment of the circuit court denying Washington University judgment notwithstanding the verdict (JNOV), holding that Plaintiff failed to submit a cognizable claim under the MRHA. Plaintiff filed a complaint against the University claiming that her request for a reasonable accommodation of her herniated discs was a protected activity. A jury returned a verdict in Plaintiff's favor against the University. The Supreme Court reversed, holding that the circuit court erred in overruling the University's JNOV motion because merely requesting an accommodation is insufficient to support a claim of retaliation under the plain language of the MHRA. View "Lin v. Ellis" on Justia Law
Tuttle v. Dobbs Tire & Auto Centers, Inc.
The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's claims for relief under the Missouri Human Rights Act (MHRA) for age discrimination and retaliation, holding that the Court was precluded from applying the MHRA to Appellant's claims. Respondent filed a motion to dismiss Appellant's claim, arguing that his petition did not state a claim upon which relief could be granted because the MHRA does not apply to an Illinois employee who faced alleged discriminatory acts in Illinois. The circuit court dismissed the petition with prejudice. The Supreme Court affirmed, holding that because Appellant was aggrieved solely in Illinois, the express language of the MHRA, coupled with the presumption against extraterritorial application of laws, precluded that Court from applying the MHRA to Appellant's claims. View "Tuttle v. Dobbs Tire & Auto Centers, Inc." on Justia Law
Cosby v. Treasurer of the State
The Supreme Court affirmed the decision of the labor and industrial relations commission affirming the award of the administrative law judge (ALJ) determining that Douglas Cosby was not entitled to permanent total disability (PTD) or permanent partial disability (PPD) benefits from the second injury fund pursuant to Mo. Rev. Stat. 287.220.3, holding that the commission did not err and that section 287.220.3, as applied to Cosby, does not violate the open courts provision or Cosby's due process and equal protection rights. Cosby injured his knee during the course of his employment. Cosby filed a workers' compensation claim against his employer and the second injury fund alleging that he was disabled as a result of his knee injury combined with his preexisting disabilities. An ALJ denied benefits, and the commission affirmed. The Supreme Court affirmed, holding (1) the commission properly interpreted section 287.220 to find that Cosby was not entitled to PPD benefits from the fund because his knee injury occurred after January 1, 2014; and (2) interpreting section 287.220.3(2) to not provide PPD benefits from the fund does not violate the Missouri open courts provision or Defendant's due process or equal protection rights. View "Cosby v. Treasurer of the State" on Justia Law
Vacca v. Missouri Department of Labor & Industrial Relations, Division of Workers’ Compensation
The Supreme Court reversed the judgment of the trial court awarding Matthew Vacca actual and punitive damages, including substantial future lost wages, on his claim that he was retaliated against for filing a complaint with the Missouri Commission on Human Rights and Equal Employment Opportunity Commission alleging disability discrimination, holding that the trial court abused its discretion in refusing to apply judicial estoppel to Vacca’s claim of future lost wages. The circuit court found Vacca claimed in this case that he could have continued to work as an administrative law judge (ALJ) for twenty more years. In Vacca’s ongoing dissolution proceeding, however, he claimed he was entitled to maintenance because he was totally unable to work due to his disability. The circuit court concluded that it was barred from applying judicial estoppel because the dissolution judgment had been remanded for further proceedings based on evidentiary errors. The Supreme Court reversed, holding (1) once a party takes inconsistent positions, there are no fixed prerequisites to application of judicial estoppel; and (2) the trial court abused its discretion in refusing to apply judicial estoppel to preclude Vacca from making the inconsistent claim that he was able to work as an ALJ for another twenty years with reasonable accommodations. View "Vacca v. Missouri Department of Labor & Industrial Relations, Division of Workers' Compensation" on Justia Law
Lampley v. Missouri Commission on Human Rights
The Supreme Court reversed the judgment of the circuit court granting summary judgment in favor of the Missouri Commission on Human Rights (Commission) on Appellants’ consolidated allegations of violations of the Missouri Human Rights Act (Act), Mo. Rev. Stat. 213.010 et seq., holding that the circuit court erred in finding that Appellants’ claims failed under Pittman v. Cook Paper Recycling Corp., 478 S.W.3d 479 (Mo. App. W.D. 2015). Specifically, the circuit court relied upon Pittman’s holding that the Act does not include claims for sex discrimination based upon sexual orientation and then extended that rationale to include claims for sex discrimination based upon sex stereotyping. The Supreme Court reversed and remanded the case, holding (1) the Commission improperly characterized Appellants’ claims as sexual orientation discrimination, and therefore, the circuit court’s reliance on Pittman was misplaced; and (2) the circuit court erred in issuing summary judgment in favor of Defendant because the Act covers sex discrimination. View "Lampley v. Missouri Commission on Human Rights" on Justia Law