Missouri Department of Corrections Missouri Cases

Savannah Radmer appealed a judgment awarding her damages and attorney fees from her former employer, the Missouri Department of Corrections, on claims of gender discrimination, hostile work environment, and retaliation. She challenged the reduction of her damages award and the constitutionality of a damages cap. MDOC cross-appealed several issues, including jury instructions and punitive damages. The appellate court dismissed the consolidated appeals, concluding that the circuit court's judgment was not final due to its failure to rule on Radmer's requests for prejudgment interest and equitable relief.

Catharine Sue Carter, as personal representative of David Carter's estate, and the Missouri Department of Corrections both appealed the circuit court's judgment following a jury verdict in Carter's favor on discrimination claims. Carter challenged the reduction of damages under a statutory cap, while the Department argued Carter failed to make a submissible case. The Supreme Court of Missouri dismissed the appeal, holding that the circuit court's judgment was not final because it failed to rule on Carter's requests for equitable relief and prejudgment interest.

Savana Atkisson, a female corrections officer, sued the Missouri Department of Corrections (DOC) for sex discrimination and hostile work environment under the MHRA, alleging that a new gender announcement policy enabled offender sexual harassment. The trial court granted summary judgment to the DOC on both claims. On appeal, Atkisson challenged only the hostile work environment claim. The appellate court affirmed the summary judgment, finding that Atkisson failed to challenge an independent basis for the trial court's decision, specifically the finding that the DOC took appropriate remedial action in response to the alleged harassment.

Pedro Carrillo sued the Missouri Department of Corrections for disability discrimination and hostile work environment under the Missouri Human Rights Act. A jury found in favor of Carrillo on both claims, awarding a single sum for compensatory damages. The DOC appealed, challenging only the disability discrimination claim. The appellate court affirmed the trial court's judgment, reasoning that because the DOC did not challenge the hostile work environment claim, the single damage award remained supported regardless of any error in the disability discrimination claim. The court also remanded the case for the trial court to determine appellate attorney fees, expenses, and post-judgment interest for Carrillo.

Keith Roy appealed the circuit court's judgment granting the Department of Corrections' motion for judgment on the pleadings. Roy sought a declaratory judgment that the 1994 version of Section 558.019.5, RSMo, which allowed the Board of Probation and Parole to convert consecutive sentences, applied to him, arguing the 2005 amendment removing this authority violated ex post facto laws. The appellate court affirmed, concluding that any risk of increased punishment due to the amendment was speculative and attenuated, thus not constituting an ex post facto violation.

Bryant Holmes sued the Missouri Department of Corrections (DOC) alleging a hostile work environment under the Missouri Human Rights Act. A jury found in favor of Holmes, and the circuit court denied DOC's motion for judgment notwithstanding the verdict (JNOV). On appeal, the DOC contended Holmes failed to present substantial evidence for two elements of his claim. The appellate court affirmed the judgment, finding sufficient evidence supported the jury's conclusion that Holmes was subjected to unwelcome harassment based on his sex and that the conduct was severe or pervasive. The case was remanded for a determination of attorney's fees on appeal.

Michael Eivins sued the Missouri Department of Corrections for age discrimination, retaliation, and hostile work environment under the MHRA. After a prior appeal reversed a summary judgment for the DOC, Eivins sought a judicial determination that certain facts were admitted by the DOC for trial purposes, which the trial court denied. On appeal, Eivins argued the trial court erred by ignoring the law of the case and denying him equal protection. The appellate court affirmed, holding that the reversal of summary judgment nullified any prior admissions for trial purposes and that Eivins was not treated differently than the DOC.

Willa Hynes's son died in the custody of the Missouri Department of Corrections (DOC), and she requested records under the Missouri Sunshine Law. The trial court granted summary judgment to Hynes, finding the DOC violated the Sunshine Law, and after a bench trial, found the violation was knowing and purposeful, ordering the DOC to produce records, pay a $5,000 penalty, and attorney's fees. The appellate court affirmed the trial court's finding that the DOC violated the Sunshine Law and that the violation was purposeful, but reversed the portion of the judgment allowing the DOC to seek a protective order before producing the records.

Beatrice Young sued her former employer, the Missouri Department of Corrections, alleging discrimination, harassment, and retaliation. A jury found in her favor on harassment claims (pre- and post-August 28, 2017) and a retaliation claim, awarding damages and attorney's fees. The appellate court reversed the judgment notwithstanding the verdict for Young's pre-August 28, 2017 gender-based harassment claim, concluding the alleged conduct was not objectively severe or pervasive enough to create a hostile work environment. As a result, the attorney's fee award was also reversed and remanded for reconsideration.

Willa Hynes appealed a partial summary judgment granted in her favor against the Missouri Department of Corrections (DOC) regarding a Sunshine Law violation, while the DOC cross-appealed. The trial court had found the DOC violated the Sunshine Law but left unresolved whether the violation was knowing or purposeful, and issues of civil penalties and attorney fees. The appellate court dismissed both appeals for lack of jurisdiction, holding that the partial summary judgment did not fully adjudicate a distinct judicial unit and was therefore not a final, appealable judgment under Rule 74.01(b).

Donald Johnson, a class X offender, appealed the trial court's grant of judgment on the pleadings in favor of the Missouri Department of Corrections. Johnson sought a declaratory judgment, arguing that a 2019 amendment to section 558.019 made him eligible for parole on his attempted robbery conviction. The appellate court affirmed the trial court's judgment, holding that the 2019 amendment does not apply to Johnson because his class X offender status and parole restriction were part of his final judgment under a prior, substantively different version of the statute.

Michael Eivins sued the Missouri Department of Corrections (DOC) alleging age discrimination, retaliation, and hostile work environment under the Missouri Human Rights Act (MHRA). The circuit court granted summary judgment to the DOC on all counts. The appellate court affirmed the circuit court's application of the "motivating factor" standard to Eivins's MHRA claims. However, it reversed the summary judgments on Eivins's age discrimination, hostile work environment, and retaliation claims, finding that genuine issues of material fact remained in dispute, and remanded the case for further proceedings.

Shelley Gray sued the Missouri Department of Corrections (DOC) for retaliation and hostile work environment under the Missouri Human Rights Act (MHRA), securing a jury verdict in her favor. The DOC appealed, challenging a jury instruction and the application of a 1.50x multiplier to Gray's attorneys' fees. The appellate court affirmed the trial court's judgment, finding the DOC failed to preserve its arguments regarding the jury instruction and the attorneys' fees multiplier. The court remanded the case for a determination of appellate attorneys' fees.

Berry Livingston, sentenced as a persistent drug offender, sought a declaratory judgment that he was parole eligible after the repeal of section 195.291, which had mandated parole ineligibility. The circuit court granted Livingston's motion for judgment on the pleadings, declaring him parole eligible. The Missouri Department of Corrections appealed, and the appellate court reversed, holding that section 1.160 prohibited the retroactive application of the repealed statute to Livingston's final sentence, meaning he remained parole ineligible. The court also denied Livingston's motion to dismiss the appeal as moot, finding an actual controversy remained.

Jason Norman, a prior drug offender, sought a declaratory judgment to retroactively apply the repeal of certain statutes, sections 195.222 and 195.296, to declare him parole eligible. The circuit court granted Norman's motion for judgment on the pleadings. The Missouri Department of Corrections appealed. The appellate court reversed the circuit court's judgment, holding that section 1.160 bars the retroactive application of the repealed statutes to Norman's final sentence, thus maintaining his parole ineligibility.

Dontarius Marks appealed the Labor and Industrial Relations Commission's denial of his workers' compensation claim for a knee injury sustained while descending stairs at work. Marks argued the injury arose out of employment, that he was not equally exposed to the risk of stairs in non-employment life, and that the finding he was only exposed to the risk of walking down stairs lacked sufficient evidence. The appellate court affirmed the Commission's award, finding that Marks failed to present credible evidence that his work activity increased the risk of injury beyond his normal non-employment life, and deferring to the Commission's credibility determination regarding his inconsistent testimony.

Dimetrious Woods, convicted of drug trafficking, sought a declaratory judgment against the Missouri Department of Corrections, arguing that the repeal of section 195.295, RSMo, rendered him eligible for parole. The circuit court sustained Woods's motion for judgment on the pleadings, leading to his parole. The Missouri Supreme Court reversed, holding that the repeal of section 195.295 had no effect on Woods's parole ineligibility, consistent with its concurrently decided case, Mitchell v. Jones.

The Missouri Department of Corrections (DOC) appealed a judgment granting partial summary judgment to corrections officers on their breach of contract claim, awarding past damages, and issuing a declaratory judgment for prospective compensation. The officers alleged DOC failed to compensate them for pre- and post-shift activities as required by their labor agreement, which incorporated FLSA standards. The appellate court affirmed the circuit court's judgment, holding that the activities were compensable and not de minimis, the breach of contract claim was not preempted by FLSA, and the class certification and declaratory judgment were proper.

Tony D. Jones, a juvenile offender sentenced to life without parole for first-degree murder and consecutive sentences for armed criminal action, sought declaratory relief to establish parole eligibility after 25 years under Section 558.047, RSMo. He argued the statute superseded other sentencing laws, allowing parole despite his consecutive sentences. The circuit court denied his petition, and the appellate court affirmed, holding that Section 558.047 only grants sentence review for the life sentence and does not eliminate or supersede parole guidelines for other consecutive sentences.

Christopher Gray, an inmate, filed a petition for declaratory judgment seeking additional jail-time credit. The trial court dismissed his petition, finding it lacked subject matter jurisdiction because Gray had not exhausted his administrative remedies. The appellate court reversed and remanded, holding that the failure to exhaust administrative remedies is an affirmative defense, not a jurisdictional bar, in light of the Missouri Supreme Court's decision in J.C.W. ex rel. Webb v. Wyciskalla.

John Newton appealed the summary judgment granted to the Missouri Department of Corrections (DOC), which denied his petition for declaratory judgment. Newton alleged the DOC miscalculated the start date of his 120-day Institutional Treatment Center program, thereby preventing his successful completion and statutory discharge to probation. The appellate court affirmed, holding that while the DOC did miscalculate the 120-day period, Newton's claim did not present a justiciable controversy entitling him to declaratory relief, as his entitlement to probation was contingent on unfulfilled conditions and speculative.

Dimetrious Woods sought a declaratory judgment against the Missouri Department of Corrections, arguing that a repealed statute eliminating parole ineligibility for prior drug offenders applied retroactively to his sentence for drug trafficking. The circuit court granted Woods's motion, but the appellate court reversed, holding that the repealed statute was part of the substantive law governing Woods's offense and therefore did not apply retroactively under section 1.160. Given the importance and recurring nature of the issue, the appellate court transferred the case to the Missouri Supreme Court.

Leontae Hill appealed the denial of his declaratory judgment petition against the Missouri Department of Corrections, seeking a declaration that he was not required to serve an 85% mandatory minimum of his life sentences for first-degree assault of a law enforcement officer. Hill argued the crime was not a "dangerous felony" under the statutes applicable at the time of his offense. The appellate court affirmed the trial court's judgment on the pleadings, holding that the crime did constitute a "dangerous felony" and that applying its prior decision in Mann v. McSwain did not violate fundamental fairness. The court also determined that Hill's claim regarding being misinformed about parole eligibility was not cognizable in a declaratory judgment action.

Michael Williams appealed the dismissal of his petition for declaratory judgment, in which he sought a declaration that the Department of Corrections was required to place him in a long-term treatment program. The trial court dismissed his petition for failure to state a claim. During the pendency of this appeal, Williams's underlying conviction and sentence were vacated in a separate post-conviction relief appeal. The appellate court found that this intervening event rendered Williams's declaratory judgment action moot and therefore dismissed the appeal.