Missouri Court of Appeals, Eastern District / Jul 23, 2024
Dawnette Geen, Appellant, vs. Missouri Department of Mental Health, Respondent.
Dawnette Geen, an in-home caregiver, appealed the trial court's judgment affirming the Missouri Department of Mental Health's decision to place her on a disqualification registry for two years due to alleged physical abuse of a consumer. The appellate court reversed, finding DMH's decision arbitrary, capricious, and unreasonable because it failed to establish an objective standard of care to measure what force was reasonable in the circumstances. The court ordered DMH to rescind its findings of physical abuse and remove Geen from the disqualification registry.