Missouri Commission on Human Rights, et al Missouri Cases

Jeanette Layton filed an age discrimination complaint with the Missouri Commission on Human Rights (Commission) against Mercy Health East Community (Mercy). After 180 days, Layton requested a right-to-sue letter, but the Commission denied it, claiming lack of jurisdiction. The circuit court granted Layton's petition for a writ of mandamus, ordering the Commission to issue the letter. The appellate court affirmed, holding that the Commission had a ministerial duty to issue the right-to-sue letter and terminate proceedings once 180 days passed and a request was made, regardless of a disputed jurisdictional issue concerning the employer's status.

Meredith Green filed a discrimination complaint against Mercy Health with the Missouri Commission on Human Rights (MCHR). After 180 days without the MCHR completing its administrative processing, Green requested a right-to-sue letter, which the MCHR initially issued but later vacated, claiming it lacked jurisdiction. Green then sought and obtained a permanent writ of mandamus from the circuit court, directing the MCHR to issue the letter. The appellate court affirmed, holding that the MCHR had a ministerial duty to issue the right-to-sue letter once the statutory conditions were met, irrespective of an unresolved jurisdictional determination regarding the employer's status.

Carol Vinson appealed the dismissal of her petition for judicial review of a Missouri Commission on Human Rights (MCHR) decision. Vinson sought to compel the MCHR to issue a right-to-sue letter against her former supervisor, Ted Wilmes, which the MCHR had refused. The appellate court affirmed the dismissal, holding that Vinson's failure to file a writ of mandamus, as required for judicial challenges to administrative proceedings, was fatal to her claim.

Stephanie Dalton appealed the dismissal of her petition for a permanent writ of mandamus against the Missouri Commission on Human Rights (MCHR). Dalton sought to compel the MCHR to investigate her retaliation claim, arguing it unlawfully relied on an EEOC investigation, acted arbitrarily by not issuing a right-to-sue letter, and violated her due process rights. The appellate court affirmed the circuit court's judgment, holding that the MCHR fulfilled its statutory duty by relying on the EEOC's investigation, its actions were not arbitrary or capricious regarding the right-to-sue letter, and Dalton's due process rights were not violated.

Matthew Stone appealed the circuit court's denial of his petition for a permanent writ of mandamus against the Missouri Commission on Human Rights (MCHR). Stone sought a right-to-sue letter after MCHR terminated his discrimination complaint, arguing MCHR's employee, T.O., lacked the authority to make a "no probable cause" determination. The appellate court reversed the judgment and remanded the case, finding the trial court misapplied the law by equating "dismissal for lack of probable cause" with "administrative closure" and failing to resolve conflicting evidence regarding T.O.'s authority to make such a determination.