Missouri Supreme Court Affirms Employment Relationship Requirement in Discrimination Case
In a recent decision, the Supreme Court of Missouri ruled on a case involving John Lisle and Meyer Electric Co., Inc. The court examined whether Meyer Electric violated section 287.780 of the Missouri workers' compensation law by refusing to hire Lisle due to his exercise of workers' compensation rights during his previous employment with the company. The court's ruling centered on the interpretation of the terms "employer" and "employee" in the context of the statute.
John Lisle, a journeyman electrician, and member of the International Brotherhood of Electrical Workers Union, was terminated by Myer Electric in 2018 shortly after he reported suffering work-related carpal tunnel syndrome. In June 2019, Lisle applied for a job posting for a journeyman electrician position at the same company, Meyer Electric, and was not hired. He alleged that Meyer Electric refused to hire him in retaliation for exercising his workers' compensation rights during their prior employment relationship and filed a lawsuit against Meyer Electric asserting a violation of section 287.780 which states in part that “No employer or agent shall discharge or discriminate against any employee for exercising any of his or her rights under this chapter….”
The Supreme Court of Missouri analyzed the language and intent of section 287.780. It found that the terms "employer" and "employee" were defined in the statute and referred to individuals presently in an employment relationship. The court concluded that the provision prohibited discriminatory acts against employees that occur only during the employment relationship and not after. The court acknowledged that section 287.780 could be reasonably interpreted to extend its protections to former employees; however, the strict construction requirement in section 287.800.1 compelled an interpretation that limited the scope of the provision to acts occurring within the employment relationship where the plain language of the statute did not explicitly include former employees. Former employees may still bring wrongful discharge claims against their employer if the discrimination occurred at the time the employee was still employed with the employer. The employee’s status at the time the discrimination occurs is what matters, not the status at the time the claim is filed.
The Missouri Supreme Court's decision clarifies the scope of protection under section 287.780 of the workers' compensation law. It establishes that the statute prohibits discrimination against employees only during their current employment relationship. Former employees are not covered under this provision.
This ruling highlights the importance of clear statutory language and the interpretation of laws based on their specific wording. It also underscores the significance of a strict construction approach when interpreting workers' compensation statutes.
Lisle v. Meyer Electric Company, SC99670 decided May 16, 2023.