Justia Labor & Employment Law Opinion Summaries

Articles Posted in Supreme Court of Missouri
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David Steele filed a lawsuit against his employer, Johnson Controls, Inc. (JCI), alleging that the company had violated § 287.780 by retaliating and discriminating against him for filing a workers' compensation claim. Steele sought compensatory and punitive damages, arguing that JCI had acted with willful, deliberate, and reckless disregard for his rights. JCI did not file an answer or responsive pleading, and Steele subsequently filed a motion for default judgment and damages. The circuit court held a hearing regarding damages, during which Steele testified about his injuries and the discriminatory treatment he received from JCI. The court entered a default judgment for Steele, awarding him $300,000 in compensatory damages and $600,000 in punitive damages.JCI filed a motion to set aside the default judgment, citing Rules 75.01, 74.05(d), and 74.06(b)(1). JCI alleged that it had good cause for the default because its registered agent mislabeled the service documents and routed them to the incorrect section of JCI's legal department. The circuit court held a hearing on JCI's motion and subsequently overruled it, concluding that JCI failed to show good cause, a meritorious defense, or excusable neglect. JCI then filed a motion for a new trial, which the circuit court also overruled. JCI appealed the decision.The Supreme Court of Missouri affirmed the circuit court's judgment. The court found that JCI had failed to prove good cause for its default as required to set aside the default judgment pursuant to Rule 74.05(d). The court also found that JCI's reliance on Rules 75.01 and 74.06(b)(1) as alternate bases to set aside the default judgment was incorrect. Finally, the court ruled that JCI's defaulted claims asserting the circuit court plainly erred by awarding punitive damages in violation of § 510.2612 were not reviewable. View "Steele v. Johnson Controls, Inc." on Justia Law

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The Supreme Court of Missouri reversed a lower court's dismissal of a lawsuit brought by workers against Harley-Davidson Motor Company Operations, Inc., and Syncreon.US. The workers, who are Black or People of Color, alleged that the companies created a hostile work environment and aided and abetted racial discrimination in violation of the Missouri Human Rights Act. The workers detailed numerous racially charged incidents at a manufacturing and assembly facility operated by Harley-Davidson and staffed by workers provided by Syncreon.US. The incidents included frequent racial insults, physical division of workers based on race, and multiple instances of hate symbols and threats found in the facility. The court found that the workers' allegations, if true, could establish the elements of a hostile work environment claim and aiding and abetting claims. The case was remanded back to the lower court for further proceedings. View "Matthews vs. Harley Davidson" on Justia Law

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The Supreme Court affirmed the final award of the labor and industrial relations commission affirming and adopting an administrative law judge's award of permanent total disability benefits to Jannie Harper under the Missouri Workers' Compensation Law, holding that the commission's decision was supported by competent and substantial evidence.Harper filed a claim for workers compensation against Springfield Rehab and Health Center and Premier Group Insurance Company Corvel Enterprise Company (collectively, Springfield Rehab). The commission awarded Harper permanent and total disability benefits, finding that Harper suffered a compensable injury arising from a workplace accident. The Supreme Court affirmed, holding that competent and substantial evidence supported the commission's final award of permanent total disability compensation and future medical care. View "Harper v. Springfield Rehab & Health Care Center" on Justia Law

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The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission finding that Maryann Gray's applications for review were timely filed pursuant to Mo. Rev. Stat. 287.480 and overruling Hawthorn Children's Psychiatric Hospital's motion to strike, holding that the Commission did not err in finding that Gray's applications were timely filed.Gray, a registered nurse at Hawthorn, filed applications for review of the denial of her claims for injuries sustained during her employment. After a hearing, the Commission found Gray timely filed her applications and affirmed the denial of benefits as to a 2012 injury but ordered Hawthorn to pay Gray partial permanent disability benefits for 2013 and 2014 injuries. The Supreme Court affirmed, holding that the Commission did not err in finding that Gray's applications were timely filed under section 287.480. View "Gray v. Hawthorn Children's Psychiatric Hospital" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court in favor of Meyer Electric Company on John Lisle's claim that Meyer Electric violated Mo. Rev. Stat. 287.780 by refusing to hire him because he exercised his chapter 287 rights during his prior employment relationship with the company, holding that there was no error.On appeal, Lisle argued that the circuit court misapplied the provisions of section 287.780 by requiring him to establish that he was an "employee" at the time Meyer Electric discriminated against him for exercising his workers' compensation rights. The Supreme Court disagreed, holding (1) as strictly construed, section 287.780 gives an employee a civil action for damages against his or her employer for discharging or discriminating against the employee while employed because the employee exercised a right established under chapter 287; and (2) because it was an uncontroverted material fact that Lisle was not an employee of Meyer Electric when it refused to hire him, Meyer Electric established its right to judgment, as a matter of law. View "Lisle v. Meyer Electric Co., Inc." on Justia Law

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The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission affirming and adopting the ALJ's final award denying Appellant's claim for benefits from the Second Injury Fund, holding that the Commission did not abuse its discretion in affirming the ALJ's denial of Appellant's post-hearing motions to reopen the record and submit additional evidence.Before the ALJ issued her final award, the Supreme Court decided Cosby v. Treasurer of Missouri, 579 S.W.3d 202 (Mo. banc 2019), which reached a different interpretation of Mo. Rev. Stat. 287.220.3 than that reached by the court of appeals in Gattenby v. Treasurer of Missouri, 516 S.W.3d 859 (Mo. App. 2017). Before the ALJ's final award, Appellant filed a motion to reopen the record for a supplemental hearing based on Cosby. The ALJ overruled the motion and issued her award. The Commission affirmed. The Supreme Court affirmed, holding that the Commission did not abuse its discretion in overruling Appellant's motions to reopen the record and submit additional evidence. View "Weibrecht v. Treasurer of Mo. as Custodian of Second Injury Fund" on Justia Law

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The Supreme Court reversed the judgment of the circuit court entering summary judgment for Employer and dismissing Employee's class action claiming that Employer violated the Missouri Prevailing Wage Act by failing to pay its employees the prevailing wage for work performed on properties in Kansas City, Missouri, holding that a genuine dispute existed, precluding summary judgment.Employee, individually and on behalf of a class of all similarly situated, filed a petition alleging that Employer violated the State's prevailing wage act and minimum wage law. The circuit court sustained Employer's motion for summary judgment as to all claims, and the court of appeals affirmed. The Supreme Court reversed, holding (1) the record supported two plausible but contrary inferences as to whether Employee was employed "on behalf of any public body engaged in the construction of public works" within the meaning of the Prevailing Wage Act; and (2) therefore, a genuine dispute of material fact existed, barring summary judgment. View "Brockington v. New Horizons Enterprises, LLC" on Justia Law

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The Supreme Court reversed the judgment of the circuit court in favor of several unions (Unions) and issuing a permanent injunction enjoining the State from altering existing collective bargaining agreements with the Unions pursuant to Senate Bill No. 1007 and ordering the State to bargain in good faith with the Unions without constraint from SB 1007, holding that the circuit court's judgment erroneously declared and applied the law.SB 1007 removed most state employees from the merit system by designating their employment statuses as at-will. The circuit court determined that SB 1007 did not impact collective bargaining or mandate at-will employment and that SB 1007 violated Mo. Const. art. I, 29 and 13. The Supreme Court reversed, holding (1) SB 1007 mandates at-will employment and restricts the State's ability to agree to terms of employment inconsistent with at-will employment; and (2) SB 1007 does not violate the right to bargain collectively as guaranteed by article I, section 29 of the Missouri Constitution. View "American Federation of State, County & Municipal Employees, AFL-CIO, Council 61 v. State" on Justia Law

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The Supreme Court reversed the judgment of the circuit court issuing a permanent writ of mandamus in favor of Jim Swoboda, holding that the circuit court's decision was erroneous because Swoboda failed to establish that he was entitled to mandamus relief.Swoboda filed a charge of discrimination with the Missouri Commission on Human Rights against his employer and Armstrong Teasdale, LLP (the Law Firm), alleging retaliation, disability, and aiding and abetting as types of discrimination he faced in retaliation for participating in a discrimination case brought by another officer. The Commission determined that it lacked jurisdiction over the matter because there was no employer-employee relationship between Swoboda and the Law Firm. The circuit court issued a writ of mandamus finding that the Commission erred in dismissing the charge without first taking certain steps. The Supreme Court reversed, holding that the issuance of mandamus relief was foreclosed where, rather than seeking to enforce a previously delineated right, Swoboda attempted to adjudicate whether his claim was permissible under applicable statutes. View "State ex rel. Swoboda v. Missouri Commission on Human Rights" on Justia Law

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The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission denying Claimant's claim for permanent total disability (PTD) benefits from the Second Injury Fund, holding that the Commission appropriately found that Claimant was not permanently and totally disabled.Claimant filed an amended workers' compensation claim against Employer, alleging that his primary work-related injuries were "bilateral upper extremities" and asserting a claim against the Fund for PTD benefits due to a prior injury to his bilateral lower extremities. An administrative law judge denied PTD benefits, and the Commission affirmed. The Supreme Court affirmed, holding that Claimant failed to carry his burden of persuasion in demonstrating that he was entitled to PTD benefits. View "March v. Treasurer of Missouri" on Justia Law