Missouri Court of Appeals, Western District / Apr 5, 2022
Garrett Loomis vs. Scott Bowers and Lea Booker
Garrett Loomis sued Scott Bowers and Lea Booker, security guards at Ameristar Casino, for negligence and negligent infliction of emotional distress after they allegedly forced him to leave due to a disability mistaken for intoxication. The trial court dismissed Loomis's common law claims, finding them preempted by the Missouri Human Rights Act (MHRA). The appellate court affirmed, holding that 2017 amendments to the MHRA did not eliminate individual liability for discrimination in public accommodation, and therefore, the MHRA continues to preempt common law claims in this area.