Scott Caldwell sued UniFirst Corporation and Michael Dean Seever II in the Circuit Court of St. Louis County, Missouri, raising claims of disability discrimination and retaliation under the Missouri Human Rights Act (MHRA) and retaliation under Missouri’s Workers’ Compensation Law. The jury found in favor of Caldwell on all claims, but the trial court granted judgment notwithstanding the verdict (JNOV) to UniFirst and Seever. Caldwell appealed the trial court’s decision to the Missouri Court of Appeals, Eastern District.
Factual Overview
Scott Caldwell worked as a District Service Manager (DSM) at UniFirst Corporation’s St. Louis office from April 2012 to July 2015. In January 2014, Caldwell sustained a back injury while covering a delivery route. Despite receiving accommodations, such as having a helper assist with lifting, Caldwell’s condition worsened, requiring surgery. In March 2015, Caldwell informed his supervisor, Michael Dean Seever II, of his intention to file a workers’ compensation claim. Shortly after, Respondents forced Caldwell to take unpaid leave, claiming he could not perform the essential functions of his job. Caldwell underwent surgery in May 2015 and was expected to return to work without restrictions by August 3, 2015. However, on July 27, 2015, Seever informed Caldwell that his position had been replaced, effectively terminating his employment.
Legal Analysis
MHRA Disability Discrimination: The court found that Caldwell presented substantial evidence to support the jury’s finding that he could perform the essential functions of his job with or without reasonable accommodation. The court also determined that Caldwell’s disability was a contributing factor in his termination, based on direct evidence of discriminatory animus by Seever. Therefore, the trial court erred in granting JNOV on Caldwell’s disability discrimination claim.
MHRA Retaliation: The court concluded that Caldwell’s May 8 email to Respondents constituted substantial evidence of his opposition to disability discrimination. The email expressed Caldwell’s disagreement with being forced to take unpaid leave due to his disability and his belief that he could perform the essential functions of his job. Thus, the trial court erred in granting JNOV on Caldwell’s MHRA retaliation claim.
Workers’ Compensation Retaliation: The court found that the three-month gap between Caldwell’s filing of a workers’ compensation claim and his termination was insufficient to establish a causal relationship without additional evidence. The court determined that the record lacked probative facts supporting the jury’s finding that the workers’ compensation claim was a contributing factor in Caldwell’s termination. Consequently, the trial court did not err in granting JNOV on this claim.
The Missouri Court of Appeals affirmed the trial court’s grant of JNOV on the workers’ compensation retaliation claim but reversed the trial court’s judgment on the MHRA disability discrimination and retaliation claims, remanding the case for reinstatement of the jury’s verdicts on those counts.
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