Plaintiff Matthew Valdivia sued defendant State of Missouri Department of Corrections in the Circuit Court of Jackson County raising claims of retaliation, hostile work environment, associational discrimination, and disability discrimination under the Missouri Human Rights Act. Before the court is Valdivia’s motion to dismiss the Department of Corrections’ appeal as untimely.
Statement of Undisputed Facts
On December 27, 2019, Valdivia filed a petition for damages against his former employer, the Missouri Department of Corrections, later filing an amended petition on April 13, 2020. The petition included four counts under the Missouri Human Rights Act: retaliation, hostile work environment, associational discrimination, and disability discrimination.
Trial began on June 5, 2023, and on June 9, 2023, Valdivia submitted two claims to the jury regarding hostile work environment based on disability and hostile work environment based on retaliation. The jury returned verdicts in favor of Valdivia on both claims, awarding $165,258 in actual damages and $1,229,629 in punitive damages.
On June 14, 2023, the circuit court entered judgment on the jury verdicts in a written document titled “Jury Trial Minutes and Judgment.” The judgment ordered that statutory interest would accrue from the date of judgment but did not specify an interest rate. The judgment also stated that the court retained jurisdiction to determine Valdivia’s claim for attorney fees.
Valdivia filed a motion for attorneys’ fees, costs, and post-judgment interest on June 30, 2023. On October 27, 2023, the circuit court entered its “Judgment as to Attorneys’ Fees.” The Department of Corrections filed a motion for judgment notwithstanding the verdict on November 27, 2023, which the court did not rule upon. The Department of Corrections filed its notice of appeal on February 29, 2024.
Legal Analysis
Timeliness of Appeal
The court analyzed whether the Department of Corrections’ notice of appeal was timely filed. Valdivia argued that the June 14, 2023 judgment was final and that, because no timely after-trial motions were filed, the judgment became final for appeal purposes on July 14, 2023, requiring the notice of appeal to be filed by July 24, 2023.
The court determined that the June 14, 2023 judgment was final because it was in writing, signed by the judge, and resolved all underlying claims that the trial court had authority to determine at that time. The Department of Corrections contended that the judgment was not final because it failed to specify an interest rate when ordering that statutory interest would accrue.
The court distinguished the case from McGuire v. Kenoma, LLC, noting that here the circuit court clearly intended to include post-judgment interest in its judgment. The court found that failure to include a statutorily required post-judgment interest rate does not impact the finality of a judgment, citing SKMDV Holdings, Inc. v. Green Jacobson, P.C.
Effect of Attorney Fee Motion on Finality
The court addressed whether Valdivia’s June 30, 2023 motion for attorneys’ fees affected the finality of the June 14, 2023 judgment. The court determined that this motion was not a motion to amend the judgment to include post-judgment interest, as it did not reference the June 14, 2023 judgment and only requested post-judgment interest for the attorneys’ fees judgment. Under Rule 74.16(b)(3), a motion for attorney’s fees is an independent action that does not suspend the finality of the underlying judgment.
Attorneys’ Fees on Appeal
The court considered Valdivia’s motion for attorneys’ fees incurred on appeal. Section 213.111.2 authorizes courts to award reasonable attorney fees to the prevailing party, including fees incurred on appeal. The court found that Valdivia was the prevailing party in securing dismissal of the appeal and granted his motion for attorneys’ fees.
The court dismissed the Department of Corrections’ appeal as untimely and granted Valdivia’s motion for attorneys’ fees, remanding to the trial court to determine and award reasonable attorneys’ fees for the appeal.
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