Johnson Controls, Inc. Missouri Cases

David Steele obtained a default judgment against Johnson Controls, Inc. (JCI) for workers' compensation retaliation, including compensatory and punitive damages. JCI moved to set aside the default judgment, arguing good cause due to misrouted service documents and asserting alternate bases under Rules 75.01 and 74.06(b)(1), and plain error regarding punitive damages. The Missouri Supreme Court affirmed the circuit court's denial of JCI's motion, holding that JCI failed to prove good cause, that Rules 75.01 and 74.06(b)(1) do not provide alternative grounds, and that plain error review of the underlying default judgment's punitive damages award was unavailable.

David Steele sued his employer, Johnson Controls, Inc. (JCI), alleging workers' compensation retaliation and discrimination. After JCI failed to respond, the trial court entered a default judgment against JCI, awarding Steele compensatory and punitive damages. JCI appealed the denial of its motion to set aside the default judgment and the punitive damages award. The appellate court affirmed, finding the trial court did not abuse its discretion in denying JCI's motion to set aside for lack of good cause and a meritorious defense, and that JCI was not entitled to appellate review of the punitive damages award due to procedural failures.