Justia Labor & Employment Law Opinion Summaries

Articles Posted in Supreme Court of Missouri
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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

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The Supreme Court reversed the judgment of the circuit court dismissing Plaintiff's complaint against Independence School District alleging that he had been fired in retaliation for filing a workers' compensation claim, in violation of Mo. Rev. Stat. 278.780, holding that the general assembly expressly waived whatever immunity the school district might have had.In dismissing Plaintiff's complaint, the circuit court found that the school district enjoyed sovereign immunity from Plaintiff's workers' compensation retaliation claim. On appeal, Plaintiff argued that workers' compensation claims are authorized against the school district because the legislature included state and political subdivisions such as school districts as employers for purposes of the Workers' Compensation Law. The Supreme Court agreed and reversed, holding that, considered together, sections 278.780 and Mo. Rev. Stat. 287.030 reflect an express showing of legislative intent to waive the school district's sovereign immunity for Plaintiff's workers' compensation retaliation claim. View "Poke v. Independence School District" on Justia Law

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The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission reversing the administrative law judge's (ALJ) award of permanent and total disability (PTD) benefits against the Second Injury Fund, holding that the Commission's findings were supported by substantial and competent evidence.Christopher Klecka suffered a compensable work-related injury to his left shoulder. After settling the primary claim with his employer Klecka brought a claim against the Fund, alleging that his primary injury combined with his prior injuries rendered him permanently and totally disabled (PTD). An ALJ issued an award against the fund for PTD benefits. The Commission reversed. The Supreme Court affirmed, holding that Klecka failed to establish that his primary injury and sole qualifying preexisting disability entitled him to PTD benefits from the Fund under Mo. Rev. Stat. 287.220.3. View "Klecka v. Treasurer of Missouri" on Justia Law

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The Supreme Court dismissed this appeal from the decision of the Labor and Industrial Relations Commission (Commission) reversing the administrative law judge's award and denying Claimant permanent total disability benefits, holding that Claimant's brief preserved nothing for appellate review because it failed to comply with the mandatory and straightforward rules governing the contents of an appellant's briefs.After the Commission denied Claimant's claim, Claimant appealed. The Supreme Court dismissed the appeal, holding that each of Claimant's points on appeal was defective because each point relied on wholly failed to follow the simple template provided in Rule 84.04. View "Lexow v. Boeing Co." on Justia Law

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The Supreme Court reversed the circuit court's judgment in favor of Danny Brock on his negligence claim against Mark Edwards, holding that the circuit court erred in overruling the motions for directed verdict and judgment notwithstanding the verdict (JNOV) filed by Peter Dunne, defendant ad litem for Edwards.Brock was injured in a work-related accident involving co-worker Edwards. Brock filed a petition alleging a negligence claim against Edwards. Edwards died before trial, and Dunne was substituted as defendant ad litem. The jury returned a verdict in Brock's favor, and the circuit court entered judgment for $873,000 in Brock's favor. The Supreme Court reversed, holding that the circuit court erred in overruling Dunne's motions for directed verdict and JNOV because Edwards was immune from liability pursuant to Mo. Rev. Stat. 287.120.1 and Brock failed to make a submissible case of common law negligence. View "Brock v. Dunne" on Justia Law

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The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission finding that Defendant was not entitled to an award of workers' compensation benefits because his injury did not arise out of and in the course of his employment, holding that there was no error.Defendant, a field service specialist for DISH Network, Inc,. was an a car accident after he choked on a sandwich and blacked out while traveling to his first appointment. Defendant sought workers' compensation benefits. The ALJ awarded benefits, but the Commission denied compensation because Defendant failed to prove his injury arose out of and in the course of his employment. The Supreme Court affirmed, holding that Defendant failed to establish that his injury arose out of and in the course of his employment. View "Boothe v. DISH Network, Inc." on Justia Law

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The Supreme Court vacated the judgment of the circuit court reversing the decision of the Board of Education of the Jefferson City Public School District to terminate Tammy Ferry's contract with the District, holding that the Board had the authority to terminate the contract.The Board decided to terminate Ferry's contract after she transferred confidential student information from the District's Google for Education account to her personal Google account. The circuit court vacated the Board's decision, finding that Ferry had not "disclosed" confidential student information, as that term is defined in the Family Educational Rights and Privacy Act of 1974 (FERA), 20 U.S.C. 1232g. The Supreme Court vacated the circuit court's judgment, holding (1) the Board's findings that Ferry violated the Board's policies and procedure and did so willfully were supported by competent and substantial evidence; and (2) the Teacher Tenure Act authorized the Board to terminate Ferry's indefinite contract with the District. View "Ferry v. Board of Education of Jefferson City Public School District" on Justia Law

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The Supreme Court affirmed in part and vacated in part the judgment of the circuit court awarding a class of Missouri corrections officers $113 million plus post-judgment interest for breach of contract, holding that the circuit court's determination that all preshift and postshift activities are compensable was erroneous.On appeal, the Missouri Department of Corrections (MDOC) argued that the circuit court erroneously determined that MDOC was liable on the corrections officers' breach of contract claims for time spent performing all preshift and postshift activities. The Supreme Court held (1) the circuit court erred in determining that all corrections officers' preshift and postshift activities were compensable principal activities that must be compensated; (2) because the award of damages and the court's declaratory and injunctive relief were based on the erroneous finding of liability, those rulings were erroneous; and (3) the circuit court correctly determined that MDOC must compensate corrections officers for time spent retrieving keys and radios and time spent monitoring and supervising offenders while not on post. View "Hootselle v. Missouri Department of Corrections" on Justia Law

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The Supreme Court vacated the Labor and Industrial Relations Commission awarding permanent total disability (PTD) benefits to Jonathan Parker under Mo. Rev. Stat. 287.220.2, holding that the Labor and Industrial Relations Commission erred in applying subsection 2 of section 287.220 rather than subsection 3 of the statute, and remand was required.Before the Supreme Court, the Second Injury Fund argued that Parker should be denied benefits under subsection 3. Parker, in turn, argued that the Supreme Court should award him benefits under subsection 3. The Supreme Court vacated the Commission's decision, holding (1) under Mo. Const. art. V, 18, the Supreme Court is permitted to review only the decisions and findings of the Commission, not to make such decisions in the first place; and (2) therefore, remand to the Commission was required to determine whether Parker was entitled to benefits under subsection 3. View "Treasurer of State as Custodian of the Second Injury Fund v. Parker" on Justia Law