Plaintiff Annie Williams sued defendants Hutcheson Enterprises, Inc. and Title Cash of Missouri, Inc. in the Circuit Court of Butler County, Missouri, raising claims of unlawful discrimination and retaliation under the Missouri Human Rights Act (MHRA). The trial court granted summary judgment in favor of Hutcheson, and Williams appealed to the Missouri Court of Appeals, Southern District.
Factual Overview
Annie Williams worked as a manager at a store owned and operated by Title Cash of Missouri, Inc. from 2017 until her termination in 2018. Williams filed a lawsuit alleging unlawful discrimination and retaliation under the MHRA against Hutcheson Enterprises, Inc., claiming that Hutcheson did business in Missouri as Title Cash. Williams later amended her petition to add Title Cash as a defendant.
Hutcheson filed a motion for summary judgment, arguing that it was not Williams’ employer and therefore could not be held liable under the MHRA. Hutcheson provided evidence that Williams was employed by Title Cash, including her employment agreement, tax documents, and the fact that she was terminated by a Title Cash manager. Williams admitted most of these facts but argued that Hutcheson and Title Cash should be considered joint employers.
The trial court granted Hutcheson’s motion for summary judgment. Williams appealed this decision to the Missouri Court of Appeals.
Legal Analysis
Employer-Employee Relationship Requirement
The court first addressed whether an employer-employee relationship is required for MHRA discrimination claims. Citing previous cases and the Missouri Supreme Court’s reasoning in State ex rel. Swoboda v. Missouri Comm’n on Human Rights, the court concluded that an employer-employee relationship is indeed required for MHRA discrimination claims.
Definition of “Employer” Under MHRA
The court examined the definition of “employer” under the MHRA, noting that the 2017 amendment to the statute removed language about persons “acting in the interest of an employer.” The current definition requires an employer to directly employ six or more employees in the state.
Joint Employer Theory
Williams argued that Hutcheson and Title Cash should be considered joint employers. The court rejected this argument for two reasons:
- Inapplicability of Pre-2017 Joint Employer Analysis: The court found that Williams’ joint employer argument relied on cases decided under the pre-2017 version of the MHRA. The court noted that no Missouri cases have applied the joint employer analysis to the post-2017 definition of “employer” in the MHRA.
- New Theory Not in Original Petition: The court pointed out that Williams’ joint employer theory was raised for the first time in her opposition to Hutcheson’s summary judgment motion and was not within the scope of her original petition.
Genuine Issue of Material Fact
The court concluded that Williams failed to show a genuine issue of material fact regarding her employment by Hutcheson. The evidence presented, including Williams’ admissions to Hutcheson’s statements of uncontroverted material facts, demonstrated that she was employed by Title Cash, not Hutcheson.
The Missouri Court of Appeals affirmed the trial court’s grant of summary judgment in favor of Hutcheson Enterprises, Inc., finding that Williams failed to establish an employer-employee relationship with Hutcheson as required under the MHRA.
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