Missouri Court of Appeals, Eastern District / Mar 1, 2022
Amanda Gill, Appellant, v. City of St. Peters, Respondent.
Amanda Gill appealed the circuit court's dismissal of Count II of her petition, which alleged sex discrimination under the Missouri Human Rights Act (MHRA) based on a disparate impact theory. The circuit court dismissed the claim, finding it time-barred and that Missouri courts do not recognize a disparate impact claim under the MHRA. The appellate court affirmed the dismissal, holding that Gill's claim was time-barred as her transfer was a discrete act not subject to the continuing violation theory, and that the Lilly Ledbetter Act does not extend MHRA filing periods. The court further held that Missouri courts have not recognized a disparate impact claim under the MHRA, and Gill failed to plead facts to support such a claim.