Charles Harris sued the Missouri Department of Corrections, Alana Boyles, and Lisa Clark in the Circuit Court of Cole County, Missouri, raising claims of discrimination and retaliation under the Missouri Human Rights Act. The trial court entered a default judgment on liability in favor of Harris and awarded $750,000 in compensatory damages and $250,000 in punitive damages after a bench trial on damages, and the defendants appealed to the Missouri Court of Appeals, Western District.
Factual Overview
Harris filed his petition on May 14, 2019, alleging that defendants subjected him to racial discrimination, harassment, retaliation, and a hostile work environment during his employment at the Chillicothe Correctional Center. On July 29, 2019, defendants filed a motion for change of venue to Livingston County, a motion to dismiss, and a motion for more definite statement, none of which received rulings from the trial court.
In April 2020, defendants filed a renewed motion for change of venue, which the trial court denied on August 13, 2020. Harris subsequently filed amended petitions in November 2020 and June 2021. The trial court granted defendants’ motion to dismiss three of the seven counts in Harris’s second amended petition in October 2021, leaving four counts remaining.
After a joint motion to continue trial in March 2022, no further action occurred until June 2023, when defendants sought another continuance due to new counsel assignment. Harris opposed this motion and filed for an interlocutory order of default judgment in July 2023, arguing that defendants failed to timely answer his second amended petition. Despite defendants’ attempts to file an answer out of time and oppose the default motion, the trial court entered an interlocutory judgment of default on August 16, 2023.
Defendants filed a motion to set aside the default judgment in October 2023, which the trial court denied through a docket entry on October 11, 2023. After a bench trial on damages, the trial court entered final judgment on February 22, 2024, awarding Harris $1 million in total damages.
Legal Analysis
Appealability of Default Judgment Motion: The court addressed whether defendants could appeal the denial of their motion to set aside the default judgment. The court ruled that a motion to set aside a default judgment under Rule 74.05(d) constitutes an independent equitable action requiring a separate final judgment to be appealable. Since the trial court’s denial was made only through an unsigned docket entry rather than a formal judgment, no appealable judgment existed on this issue. The court rejected defendants’ argument that the final damages judgment incorporated all prior orders, finding no authority supporting this position for independent actions.
Direct Appeal from Default Judgment: The court explained that default judgments generally cannot be directly appealed except in narrow circumstances involving challenges to the court’s subject matter jurisdiction. Defendants’ arguments that the trial court lacked authority due to venue issues and that the default judgment was actually a judgment on the merits did not fall within this exception. The court distinguished between venue and subject matter jurisdiction, noting that improper venue does not divest a court of jurisdiction.
Mootness of Substantive Challenges: Since defendants failed to obtain a proper appeal of the denial of their motion to set aside the default judgment, their substantive challenges to the default judgment in Points I and II became moot. The court emphasized that allegations of error relating to the merits of a default judgment are generally moot unless the default judgment is set aside.
Attorneys’ Fees: The court granted Harris’s motion for attorneys’ fees on appeal under the Missouri Human Rights Act, which authorizes reasonable attorney fees for prevailing parties. Since Harris successfully defended against the appeal that was ultimately dismissed, he qualified as the prevailing party. The court remanded to the trial court for determination of the reasonable amount of appellate attorneys’ fees.
The Missouri Court of Appeals dismissed the appeal for lack of a final appealable judgment on the motion to set aside the default judgment, rendering moot the defendants’ challenges to the underlying default judgment, and remanded for determination of the plaintiff’s appellate attorneys’ fees.
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