M.N., A Minor by and Through His Biological Mother and Next Friend, S.N. Missouri Cases

M.N., a minor, through his mother, sued North Kansas City School District and Kelly Services, Inc., alleging racial discrimination in a public accommodation under the Missouri Human Rights Act after a substitute teacher used a racial slur against him. The trial court granted summary judgment for the defendants, finding no evidence they knew or should have known of the teacher's conduct. The appellate court reversed, holding that the trial court applied an incorrect direct liability standard instead of the vicarious liability standard of respondeat superior, and remanded the case for further proceedings.