Plaintiff Jeanette Layton sued Mercy Hospital East Communities, Mercy Health, Mercy Clinic East Communities, and MHM Support Services (collectively, Respondents) in the Circuit Court of St. Louis County, raising a claim of age discrimination under the Missouri Human Rights Act (MHRA). The circuit court granted summary judgment in favor of Respondents, and Layton appealed the decision to the Missouri Court of Appeals, Eastern District.
Factual Overview
Jeanette Layton filed a complaint with the Missouri Commission on Human Rights (Commission) alleging Respondents unlawfully discriminated against her due to her age. The Commission issued a notice of termination of proceedings, indicating it lacked jurisdiction because Respondents were exempted from MHRA coverage. Layton filed a petition for writ of mandamus to compel the Commission to issue a right-to-sue letter, which the circuit court granted. Respondents appealed, and the court of appeals affirmed the circuit court’s judgment.
Layton then sued Respondents in the Circuit Court of St. Louis County, alleging age discrimination under the MHRA. Respondents denied they were subject to the MHRA and asserted that MHM Support Services was Layton’s actual employer. The court granted Respondents’ motion to bifurcate discovery to first determine whether Respondents were owned or operated by a religious organization. Following discovery, Respondents moved for summary judgment, arguing they were excluded from MHRA coverage. The circuit court granted Respondents’ motion for summary judgment.
Legal Analysis
Religious Organization Exclusion: The court found that Respondents demonstrated as a matter of undisputed fact that Layton’s employer, Mercy Clinic, was operated by a religious organization, the Roman Catholic Church, and thus excluded from MHRA coverage. The court applied factors from St. Louis Christian Home v. Missouri Comm’n on Human Rights to determine whether Mercy Clinic was operated by a religious organization, considering evidence such as the Church’s role in founding, funding, controlling, and governing Mercy Clinic, as well as Mercy Clinic’s corporate bylaws, articles of incorporation, non-profit status, and religious mission.
Compliance with Rule 74.04: The court rejected Layton’s argument that summary judgment was improper because Respondents violated Supreme Court Rule 74.04 by combining multiple material facts into single paragraphs and failing to specify which evidence supported each fact. The court found that Respondents incorporated separately numbered paragraphs and specific references to supporting documentation, complying with the requirements of Rule 74.04.
Conclusion
The Missouri Court of Appeals, Eastern District, affirmed the circuit court’s grant of summary judgment in favor of Respondents, finding that Mercy Clinic was operated by a religious organization and thus excluded from MHRA coverage.
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