Missouri Court of Appeals, Eastern District / Aug 26, 2025
Rayne Littlefield, Appellant, vs. Norman Rigdon Post 5896, Veterans of Foreign Wars of The United States, Inc., Respondent.
Rayne Littlefield sued the Norman Rigdon Post 5896, Veterans of Foreign Wars (VFW), alleging sex discrimination and retaliation under the Missouri Human Rights Act (MHRA). The circuit court granted summary judgment for VFW, finding it exempt from the MHRA as a bona fide private membership club. On appeal, Littlefield argued that VFW's public events and advertising negated its exempt status. The appellate court affirmed, holding as a matter of first impression that VFW's public activities do not, by themselves, alter its status as a bona fide private membership club, thus exempting it from MHRA liability.