Charles Harris, a former Missouri Department of Corrections employee, sued the Department and two supervisors under the Missouri Human Rights Act, alleging racial discrimination, harassment, retaliation, and a hostile work environment at the Chillicothe Correctional Center. The trial court denied a change-of-venue motion, later entered an interlocutory default judgment on liability after the defendants failed to timely answer an amended petition, and ultimately awarded compensatory and punitive damages. On appeal, the Missouri Court of Appeals dismissed the defendants’ challenge, holding that no final appealable judgment existed because the trial court had not yet ruled on their motion to set aside the default, depriving the appellate court of jurisdiction over the venue, default, and related claims. The court also awarded Harris attorneys’ fees on appeal and remanded the fee determination to the trial court.
The Missouri Court of Appeals addressed an appeal by the Missouri Department of Corrections and two officials from a trial court award of attorneys' fees to former employee Charles Harris. Harris had obtained a default judgment on his claims of racial discrimination, harassment, and retaliation under the Missouri Human Rights Act, followed by a damages award after an evidentiary hearing. Appellants contended the trial court lost authority after their change-of-venue motion was deemed granted by operation of law, that the default was improperly entered, and that the court should have set it aside for good cause. The appellate court affirmed the fee award, holding that Harris remained the prevailing party because his related appeal of the underlying default judgment had been dismissed for lack of a final appealable order, and the appellants raised no challenge to the amount or reasonableness of the fees. The court also granted Harris fees on appeal and remanded the case for the trial court to determine that amount.
In State v. Eggleston, the defendant was convicted after a bench trial of one count of possession of a controlled substance based on methamphetamine discovered in a vehicle he was driving during a traffic stop in Jefferson City. The Missouri Court of Appeals reversed the conviction, holding that the State presented insufficient evidence to prove beyond a reasonable doubt that Eggleston knowingly possessed the drug. The court noted that the unlabeled bottle containing the substance was found in a concealed dashboard compartment not visible from outside the vehicle, with no fingerprints, statements, or other evidence connecting Eggleston to it; the female passenger showed signs of impairment, possessed related paraphernalia, and had access to the area; and Eggleston's refusal to consent to a search could not be treated as consciousness of guilt given his right to refuse and the possibility it related to the passenger.
Thomas Hasselbring, a nursing home employee, sought workers’ compensation benefits after an electric wheelchair ran over his left foot at work on November 3, 2021, leading to emergency surgery and above-knee amputation two days later due to acute ischemia from a preexisting closed popliteal artery aneurysm. The Labor and Industrial Relations Commission denied benefits, finding that the workplace accident was merely a triggering or precipitating factor and that the prevailing factor in the disability was the occluded aneurysm. On appeal, the Missouri Court of Appeals affirmed the Commission’s award. It held that the Commission’s decision was supported by sufficient competent evidence, particularly the opinion of the employer’s retained physician, and that the Commission had properly applied the prevailing-factor test to causation of the disability rather than treatment, without improperly considering the employee’s negligence or substituting its own medical judgment for expert testimony.
In Holly Hyde v. Michael Hyde, the Missouri Court of Appeals reviewed a Boone County trial court decision dismissing a former wife's motion for a nunc pro tunc order to amend the maintenance provision in the parties' 2021 divorce judgment. The wife argued that language stating maintenance would terminate upon the remarriage of either party was a clerical error under Rule 74.06(a), as the parties had not discussed or agreed to termination on the husband's remarriage. The appeals court affirmed the dismissal, holding that the judgment accurately reflected the signed separation agreement incorporated by the trial court, so any alleged mistake was not a clerical recording error that could be corrected at any time. Instead, it involved the creation or understanding of the agreement itself, which would fall under the one-year time limit of Rule 74.06(b) that had already expired.
In State of Missouri v. Juvonie Eugene Minor, the defendant was convicted by a jury of felony criminal nonsupport under section 568.040 for failing to pay court-ordered child support for his two children between August and October 2018, resulting in arrears over $87,000. Minor appealed, claiming the trial court erred by refusing to give the jury an instruction on the affirmative defense of good cause based on his alleged health problems and employment difficulties. The Missouri Court of Appeals affirmed the conviction, ruling that Minor's testimony—mentioning only unspecified health issues and a brief 2018 job without medical evidence, documentation, or details tying the issues to the charged period—did not constitute substantial evidence warranting the instruction.