Charlotte Moore v. Southwestern Bell Telephone Co. et al, No. ED111470 (Mo. App. Dec. 19, 2023) (J. Odenwald)

Charlotte Moore appealed to the Missouri Court of Appeals Eastern District the circuit court’s grant of summary judgment for Southwestern Bell Telephone Company (SWBT) and several employees. Moore sued SWBT bringing allegations of workplace discrimination under the Missouri Human Rights Act (MHRA), which includes claims of racial discrimination, disability discrimination, retaliation, and a hostile work environment.

Plaintiff’s Factual Allegations

Charlotte Moore, employed as a service representative by SWBT from 2003 to 2017, alleges racial discrimination, disability discrimination, retaliation, and a hostile work environment under the MHRA following her termination. Moore claims mistreatment mainly from her supervisor, Sharon Hyche, along with Johnny Soliz and Jacobie Jones. She argues that her termination resulted from discriminatory practices against her based on race and disability, creating a hostile work environment.

Arguments and Court’s Ruling

Racial Discrimination and Hostile Work Environment: The court found insufficient evidence of racial discrimination or a racially hostile work environment, as Moore’s testimony suggested Hyche was strict with all team members, not specifically targeting any racial group.

Disability Discrimination:  The court ruled there was no evidence that SWBT was aware of Moore’s conditions (major depressive disorder and generalized anxiety) or that these conditions contributed to her termination.

Retaliation: Regarding retaliation, the court concluded there was no evidence to suggest Moore’s termination was in retaliation for her discrimination complaints. The court attributed her termination to performance issues and policy violations.

Hostile Work Environment Claim: Moore’s claim of a hostile work environment was also denied. The court determined that her experiences, while perhaps challenging, did not meet the legal threshold of severe or pervasive harassment necessary to establish a hostile work environment.

Judgment Against Hyche: The appellate court found procedural errors in the circuit court’s grant of summary judgment for Sharon Hyche. Since Hyche did not move for summary judgment, the court concluded that it was procedurally incorrect to grant a judgment in her favor. As a result, the appellate court reversed the circuit court’s decision about Hyche and remanded the case for further proceedings. In conclusion, the appellate court affirmed the circuit court’s summary judgment for SWBT and its employees on all counts except for the judgment regarding Hyche. The case against Hyche was remanded due to procedural irregularities in the circuit court’s handling of the summary judgment in her favor.