Section 14 Missouri Human Rights Act

• Library: Employment Discrimination 2008

In the landmark decision of Daugherty v. City of Maryland Heights,
231 S.W.3d 814 (Mo. banc 2007), the Supreme Court of Missouri
held that nothing in the statutory language of the Missouri Human Rights Act (MHRA), Chapter 213, RSMo, requires a plaintiff to prove that discrimination was a substantial or determining factor in an employment decision. Rather, the Court held that it is sufficient if consideration of protected characteristics such as age contributed to the unfair treatment.

In Daugherty, 231 S.W.3d at 819 n.6, the Supreme Court noted that past MHRA cases followed a pattern of analysis articulated by the federal courts:

• If direct evidence of discrimination was presented, the courts applied the standard outlined in Price Waterhouse v. Hopkins, 490 U.S. 228 (1989), requiring that the employee produce direct...