Missouri Highways and Transportation Commission Missouri Cases

Kevin Rhodes, a former employee, and the Missouri Highways and Transportation Commission both appealed the circuit court's judgment following a jury verdict in Rhodes's favor on his claims for hostile work environment and retaliation under the Missouri Human Rights Act. Rhodes challenged the constitutional validity of a damages cap, while the Commission argued Rhodes 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 Rhodes's requests for equitable relief and prejudgment interest.

Kevin Rhodes sued the Missouri Highways and Transportation Commission (MHTC) for hostile work environment and retaliation under the Missouri Human Rights Act (MHRA), securing a jury verdict. The circuit court applied a statutory damages cap, leading MHTC to appeal the denial of its JNOV motion and Rhodes to cross-appeal the constitutionality of the damages cap. The Court of Appeals determined that Rhodes's constitutional challenge invoked the exclusive appellate jurisdiction of the Missouri Supreme Court. Consequently, the court transferred the entire case to the Supreme Court, lacking jurisdiction to address the merits of either appeal.

The Missouri Highways and Transportation Commission (MHTC) sought to implement a pay plan for its employees using funds from the State Road Fund without additional legislative appropriation. The Commissioner of Administration refused, arguing that legislative appropriation was required. The trial court granted MHTC's motion for judgment on the pleadings, concluding that Article IV, section 30(b).1 of the Missouri Constitution permits MHTC to access and use these funds without legislative action for such purposes. The appellate court affirmed, holding that the constitutional provision unambiguously dictates that the entire State Road Fund stands appropriated without legislative action for its enumerated purposes, including employing necessary personnel.

Perry Allen appealed the circuit court's grant of summary judgment to the Missouri Highways and Transportation Commission on his discrimination, retaliation, and hostile work environment claims under the MHRA. Allen argued that the trial court erred by relying on his admission that the terminating manager did not personally discriminate, asserting that other individuals with discriminatory motives influenced the decision and that his termination itself supported a hostile work environment claim. The appellate court affirmed the summary judgment, finding no evidence that other individuals influenced the termination decision and that Allen's alleged incidents of harassment were not severe or pervasive enough to create a hostile work environment.