Missouri Court of Appeals, Western District / Jun 15, 2021
Melissa A. Rasmussen vs. Illinois Casualty Company
Melissa A. Rasmussen sued SRJS, Inc., d/b/a BoJo's Bar & Grill, and its employee Tyler Rivera under Missouri's Dram Shop Act after Rebecca Milner, served by Rivera, caused a head-on collision that severely injured Rasmussen. SRJS's insurer, Illinois Casualty Company (ICC), intervened and appealed the trial court's judgment, challenging discovery restrictions and the award of punitive damages. The appellate court affirmed the trial court's judgment, finding that while the discovery ruling was erroneous, ICC failed to demonstrate prejudice, and punitive damages are recoverable under the Dram Shop Act.