Missouri State Civil Rights Complaint (MHRA)

MISSOURI STATE CIVIL RIGHTS COMPLAINT — MHRA + PARALLEL FEDERAL CLAIMS

TABLE OF CONTENTS

1. Caption
2. Introduction
3. Parties
4. Jurisdiction and Venue
5. Administrative Exhaustion
6. Factual Allegations
7. Count I — Discrimination in Employment (RSMo § 213.055)
8. Count II — Retaliation (RSMo § 213.070.1(2))
9. Count III — Discrimination in Public Accommodations (RSMo § 213.065) (if applicable)
10. Count IV — Title VII of the Civil Rights Act of 1964 (Parallel Federal Claim)
11. Count V — 42 U.S.C. § 1981 / ADEA / ADA (Parallel Federal Claims, as applicable)
12. Damages
13. Prayer for Relief
14. Demand for Trial by Jury
15. Reservation of Rights
16. Signature and Service Blocks
17. Certificate of Service
18. Missouri Practice Notes
19. Sources and References

1. CAPTION

IN THE CIRCUIT COURT OF [________________________________] COUNTY, MISSOURI

[________________________________] JUDICIAL CIRCUIT

Case No. [________________________________]

Division: [____]

PETITION FOR DAMAGES AND EQUITABLE RELIEF

(EMPLOYMENT DISCRIMINATION — MISSOURI HUMAN RIGHTS ACT AND PARALLEL FEDERAL CLAIMS)

JURY TRIAL DEMANDED

Plaintiff [PLAINTIFF NAME], by and through undersigned counsel, brings this action against Defendant [EMPLOYER NAME] and states as follows:

2. INTRODUCTION

1. This is a civil action for employment discrimination, harassment, and retaliation in violation of the Missouri Human Rights Act ("MHRA"), RSMo § 213.010 et seq., and parallel federal civil rights statutes.

2. Plaintiff alleges that Defendant subjected Plaintiff to [adverse employment actions / a hostile work environment / failure to accommodate / retaliation] because of Plaintiff's [race / color / religion / national origin / sex / ancestry / age / disability], in violation of RSMo § 213.055 and [Title VII / ADEA / ADA / 42 U.S.C. § 1981].

3. Plaintiff seeks back pay, front pay, compensatory damages, punitive damages, equitable relief, attorney's fees, costs, and pre- and post-judgment interest as authorized by RSMo § 213.111 and 42 U.S.C. § 1981a (or other applicable federal remedy provisions).

3. PARTIES

3.1. Plaintiff [PLAINTIFF NAME] ("Plaintiff") is an adult individual residing in [CITY], [COUNTY] County, Missouri, who at all relevant times was an "employee" within the meaning of RSMo § 213.010(7).

3.2. At all relevant times, Plaintiff was a member of one or more classes protected under the MHRA, namely [race / color / religion / national origin / sex / ancestry / age (40–69) / disability].

3.3. Defendant [EMPLOYER NAME] ("Defendant" or "the Company") is a [corporation / limited liability company / partnership / sole proprietorship / municipal entity / state agency] organized under the laws of [STATE], with its principal place of business at [ADDRESS] and a place of business in [COUNTY] County, Missouri, where Plaintiff worked.

3.4. At all relevant times, Defendant was an "employer" within the meaning of RSMo § 213.010(8) because Defendant had six (6) or more employees for each working day in each of twenty (20) or more calendar weeks in the current or preceding calendar year, and was engaged in an industry affecting commerce.

3.5. Defendant is also an "employer" within the meaning of 42 U.S.C. § 2000e(b) (15 or more employees), 29 U.S.C. § 630(b) (20 or more employees for ADEA), and/or 42 U.S.C. § 12111(5) (15 or more employees for ADA), as applicable.

4. JURISDICTION AND VENUE

4.1. This Court has subject-matter jurisdiction pursuant to Mo. Const. art. V, § 14 (general jurisdiction of the Circuit Courts), RSMo § 478.070 (general civil jurisdiction), and RSMo § 213.111.1 (statutory authorization of civil action under the MHRA).

4.2. Venue is proper in this Court pursuant to RSMo § 213.111.1, which provides that an action under the MHRA "may be brought in any circuit court in any county in which the unlawful discriminatory practice is alleged to have occurred." The unlawful practices alleged herein occurred in [COUNTY] County, Missouri.

4.3. The amount in controversy, exclusive of interest and costs, exceeds the jurisdictional minimum of the Circuit Court ($25,000) per RSMo § 478.225.

4.4. This Court has supplemental jurisdiction over the parallel federal counts pleaded herein and may exercise concurrent jurisdiction over Title VII, ADA, ADEA, and 42 U.S.C. § 1981 claims (Yellow Freight Sys., Inc. v. Donnelly, 494 U.S. 820 (1990)).

5. ADMINISTRATIVE EXHAUSTION

5.1. On [__/__/____], within 180 days of the most recent discriminatory act and as required by RSMo § 213.075.1, Plaintiff filed a verified Charge of Discrimination with the Missouri Commission on Human Rights ("MCHR"), MCHR Charge No. [________________].

5.2. The Charge was cross-filed with the U.S. Equal Employment Opportunity Commission ("EEOC") pursuant to the MCHR/EEOC Worksharing Agreement, EEOC Charge No. [________________], and is therefore deemed filed with the EEOC on the same date as it was filed with the MCHR (RSMo § 213.075.5; 29 C.F.R. § 1601.13).

5.3. On [__/__/____], the MCHR issued a Notice of Right to Sue pursuant to RSMo § 213.111.1, a true and correct copy of which is attached hereto as Exhibit A.

5.4. On [__/__/____], the EEOC issued a Notice of Right to Sue pursuant to 42 U.S.C. § 2000e-5(f)(1), a true and correct copy of which is attached hereto as Exhibit B.

5.5. This Petition is filed within ninety (90) days of Plaintiff's receipt of the MCHR Notice of Right to Sue and within ninety (90) days of receipt of the EEOC Notice, and within two (2) years of the alleged cause of action, in compliance with RSMo § 213.111.1 and 42 U.S.C. § 2000e-5(f)(1).

5.6. Plaintiff has therefore exhausted all administrative prerequisites to suit.

6. FACTUAL ALLEGATIONS

6.1. Plaintiff was hired by Defendant on or about [__/__/____] as a [POSITION TITLE] at Defendant's [LOCATION] facility.

6.2. Throughout Plaintiff's employment, Plaintiff performed Plaintiff's job duties competently and met or exceeded Defendant's legitimate, non-discriminatory expectations. [Cite specific performance reviews, commendations, promotions, raises, metrics.]

6.3. Plaintiff is and at all relevant times was a member of the following protected class(es) under the MHRA: [describe — e.g., African-American (race); over 40 (age); female (sex); known to have a qualifying disability under § 213.010(5)].

6.4. Beginning on or about [__/__/____], Defendant, through its supervisors, managers, and agents acting in the course and scope of their employment, engaged in the following discriminatory and harassing conduct:

• (a) [DATE] — [ACTOR / TITLE]: [Describe specific act — slur, harassment, denial of promotion, failure to accommodate, disparate discipline, demotion, etc.]
• (b) [DATE] — [ACTOR / TITLE]: [Describe.]
• (c) [DATE] — [ACTOR / TITLE]: [Describe.]
• (d) [DATE] — [ACTOR / TITLE]: [Describe.]

6.5. Similarly situated employees outside Plaintiff's protected class were treated more favorably. Specifically, [describe comparators by initials, position, dates, and the differential treatment].

6.6. On [__/__/____], Plaintiff complained internally to [HR / supervisor / manager NAME] about the discriminatory and harassing conduct. Defendant [failed to investigate / conducted a sham investigation / took no remedial action / retaliated].

6.7. On [__/__/____], Defendant [terminated / demoted / disciplined / failed to promote / refused to accommodate / constructively discharged / refused to hire] Plaintiff. Defendant's stated reason was [stated reason].

6.8. Defendant's stated reason is pretextual because [explain — shifting reasons, lack of factual basis, comparator treatment, temporal proximity to protected activity, deviation from policy, statistical pattern].

6.9. Plaintiff's protected status was the "motivating factor" in Defendant's adverse employment action — i.e., it actually played a role in and had a determinative influence on the adverse decision (RSMo § 213.010(19); § 213.111.5).

6.10. As a direct and proximate result of Defendant's conduct, Plaintiff has suffered and continues to suffer lost wages and benefits, lost earning capacity, emotional distress, humiliation, embarrassment, mental anguish, damage to reputation, and other compensable damages.

7. COUNT I — DISCRIMINATION IN EMPLOYMENT (RSMo § 213.055)

7.1. Plaintiff re-alleges and incorporates by reference paragraphs 1 through 6.10 as though fully set forth herein.

7.2. RSMo § 213.055.1(1)(a) provides that it is an unlawful employment practice for an employer "because of the race, color, religion, national origin, sex, ancestry, age or disability of any individual: (a) To fail or refuse to hire or to discharge any individual, or otherwise to discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual's race, color, religion, national origin, sex, ancestry, age or disability."

7.3. Defendant violated RSMo § 213.055 by [adverse action] against Plaintiff because of Plaintiff's [protected class].

7.4. Plaintiff's [protected class] was the motivating factor in Defendant's adverse employment action — i.e., it actually played a role in and had a determinative influence on the adverse decision, as required by RSMo § 213.010(19) and § 213.111.5.

7.5. Defendant's conduct was the direct proximate cause of Plaintiff's claimed damages.

7.6. Defendant's conduct was outrageous because of Defendant's evil motive or reckless indifference to the rights of others, supporting an award of punitive damages under RSMo § 213.111.4.

7.7. As a direct and proximate result, Plaintiff is entitled to back pay with interest, front pay, compensatory damages, punitive damages (subject to the tiered cap of RSMo § 213.111.4), reasonable attorney's fees and costs (RSMo § 213.111.2), and such equitable relief as the Court deems appropriate.

8. COUNT II — RETALIATION (RSMo § 213.070.1(2))

8.1. Plaintiff re-alleges and incorporates by reference paragraphs 1 through 7.7 as though fully set forth herein.

8.2. RSMo § 213.070.1(2) makes it an unlawful discriminatory practice "to retaliate or discriminate in any manner against any other person because such person has opposed any practice prohibited by this chapter or because such person has filed a complaint, testified, assisted, or participated in any manner in any investigation, proceeding or hearing conducted pursuant to this chapter."

8.3. On [__/__/____], Plaintiff engaged in protected activity by [opposing discrimination internally / filing an MCHR or EEOC charge / participating in an investigation / requesting a reasonable accommodation].

8.4. Defendant was aware of Plaintiff's protected activity.

8.5. Within [____ days/weeks/months] of the protected activity, Defendant subjected Plaintiff to a materially adverse action, namely [describe].

8.6. The protected activity was the motivating factor in Defendant's retaliatory action — i.e., it actually played a role in and had a determinative influence on the adverse decision (RSMo § 213.010(19); § 213.111.5).

8.7. Defendant's stated reasons for the adverse action are pretextual.

8.8. Defendant's conduct violated RSMo § 213.070.1(2) and entitles Plaintiff to relief under RSMo § 213.111.

9. COUNT III — DISCRIMINATION IN PUBLIC ACCOMMODATIONS (RSMo § 213.065) (if applicable)

9.1. Plaintiff re-alleges and incorporates by reference paragraphs 1 through 8.8 as though fully set forth herein.

9.2. RSMo § 213.065.1 provides that all persons "shall be entitled to the full and equal use and enjoyment within this state of any place of public accommodation," and § 213.065.2 makes it unlawful "to refuse, withhold from or deny any other person, or to attempt to refuse, withhold from or deny any other person, any of the accommodations, advantages, facilities, services, or privileges made available in any place of public accommodation . . . because of race, color, religion, national origin, sex, ancestry, or disability."

9.3. Defendant operates a "place of public accommodation" within the meaning of RSMo § 213.010(15), which includes any establishment that caters or offers its services, facilities, or goods to the general public.

9.4. On [__/__/____], Defendant denied Plaintiff full and equal accommodations because of Plaintiff's [protected class] by [describe denial — refusal of service, segregation, differential treatment, ejection] at [LOCATION].

9.5. Defendant's conduct violated RSMo § 213.065 and entitles Plaintiff to relief under RSMo § 213.111.

10. COUNT IV — TITLE VII OF THE CIVIL RIGHTS ACT OF 1964 (PARALLEL FEDERAL CLAIM)

10.1. Plaintiff re-alleges and incorporates by reference paragraphs 1 through 9.5 as though fully set forth herein.

10.2. Title VII, 42 U.S.C. § 2000e-2(a)(1), prohibits an employer from discharging or otherwise discriminating against any individual with respect to compensation, terms, conditions, or privileges of employment because of race, color, religion, sex, or national origin.

10.3. Defendant is an "employer" within the meaning of 42 U.S.C. § 2000e(b) because it has fifteen (15) or more employees and is engaged in an industry affecting commerce.

10.4. Defendant subjected Plaintiff to discrimination because of Plaintiff's [race / color / religion / sex / national origin] in violation of Title VII.

10.5. Pursuant to Bostock v. Clayton County, 590 U.S. 644 (2020), Title VII's prohibition on sex discrimination encompasses discrimination based on sexual orientation and gender identity. [Plead if applicable.]

10.6. Plaintiff timely filed a Charge with the EEOC and received a Notice of Right to Sue. This Petition is filed within 90 days of Plaintiff's receipt of that Notice.

10.7. Plaintiff is entitled to all relief authorized by 42 U.S.C. § 2000e-5(g) and § 1981a, including back pay, front pay, compensatory damages, punitive damages (subject to § 1981a caps), attorney's fees, and costs.

11. COUNT V — 42 U.S.C. § 1981 / ADEA / ADA (PARALLEL FEDERAL CLAIMS, AS APPLICABLE)

11.1. Plaintiff re-alleges and incorporates by reference paragraphs 1 through 10.7 as though fully set forth herein.

11.2. [42 U.S.C. § 1981] prohibits race and ancestry discrimination in the making, performance, modification, and termination of contracts, including employment contracts. Defendant intentionally discriminated against Plaintiff on the basis of [race / ancestry] in violation of § 1981.

11.3. [ADEA, 29 U.S.C. § 623(a)] prohibits an employer from discriminating against any individual age 40 or older with respect to terms, conditions, or privileges of employment because of age. Defendant terminated/demoted/refused to hire Plaintiff because of Plaintiff's age, in violation of the ADEA.

11.4. [ADA, 42 U.S.C. § 12112] prohibits discrimination on the basis of disability, including failure to provide reasonable accommodation. Plaintiff is a "qualified individual with a disability" within the meaning of 42 U.S.C. § 12111(8). Defendant [failed to engage in the interactive process / denied a reasonable accommodation / terminated Plaintiff because of disability] in violation of the ADA.

11.5. Plaintiff has timely exhausted all federal administrative prerequisites and is entitled to all relief authorized by the applicable federal statute, including (where applicable under § 1981) damages without statutory cap.

12. DAMAGES

12.1. Economic damages. Lost wages and benefits (including health insurance, retirement contributions, and bonuses), front pay, lost earning capacity, and out-of-pocket expenses, in an amount to be proven at trial but estimated to exceed $[__________].

12.2. Compensatory damages. Emotional distress, humiliation, embarrassment, mental anguish, damage to reputation, loss of enjoyment of life, and consequential damages.

12.3. Punitive damages. Pursuant to RSMo § 213.111.4, 42 U.S.C. § 1981a, and applicable federal law, Plaintiff seeks punitive damages for Defendant's outrageous conduct undertaken with evil motive or reckless indifference to Plaintiff's protected rights.

12.4. Attorney's fees and costs. Pursuant to RSMo § 213.111.2 and 42 U.S.C. §§ 1988(b), 2000e-5(k), 12205, and 29 U.S.C. § 626(b).

12.5. Pre- and post-judgment interest. Pursuant to RSMo § 408.040 and 28 U.S.C. § 1961.

13. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully prays for judgment against Defendant as follows:

• A. Declaratory judgment that Defendant violated the Missouri Human Rights Act and the federal civil rights laws referenced herein;
• B. Permanent injunctive relief enjoining Defendant from further discriminatory and retaliatory practices, and ordering reinstatement, expungement of negative personnel records, and policy reforms as appropriate;
• C. Back pay, with interest, from the date of the adverse action through the date of judgment;
• D. Front pay in lieu of reinstatement where reinstatement is impracticable;
• E. Compensatory damages for lost benefits, emotional distress, humiliation, and reputational harm in an amount to be determined at trial;
• F. Punitive damages to the maximum extent permitted by RSMo § 213.111.4 and 42 U.S.C. § 1981a, and without statutory cap on any 42 U.S.C. § 1981 count;
• G. Reasonable attorney's fees and costs pursuant to RSMo § 213.111.2 and applicable federal fee-shifting provisions;
• H. Pre-judgment and post-judgment interest;
• I. Such other and further relief, legal or equitable, as this Court deems just and proper.

14. DEMAND FOR TRIAL BY JURY

Plaintiff demands a trial by jury on all issues so triable, pursuant to Mo. Const. art. I, § 22(a); RSMo § 213.111.6; Mo. R. Civ. P. 69.01(b); and (as to federal counts) the Seventh Amendment to the U.S. Constitution and Fed. R. Civ. P. 38.

15. RESERVATION OF RIGHTS

Plaintiff reserves the right to amend this Petition pursuant to Mo. R. Civ. P. 55.33 to add additional parties, claims, or theories of liability that arise from continuing investigation, ongoing discovery, or events occurring after the filing of this Petition (including any continuing or post-charge retaliation).

16. SIGNATURE AND SERVICE BLOCKS

Date: [__/__/____]

Respectfully submitted,

[________________________________]

[ATTORNEY NAME], Mo. Bar No. [######]

[LAW FIRM NAME]

[STREET ADDRESS]

[CITY, MO ZIP]

Telephone: [NUMBER]

Facsimile: [NUMBER]

Email: [EMAIL]

ATTORNEYS FOR PLAINTIFF

17. CERTIFICATE OF SERVICE

I hereby certify that on [__/__/____], the foregoing Petition for Damages and Equitable Relief was filed with the Clerk of the Circuit Court of [________________________________] County, Missouri, via Missouri's electronic filing system, and that service of process upon Defendant will be effected through the Sheriff or a special process server pursuant to Mo. R. Civ. P. 54.

[________________________________]

[ATTORNEY NAME], Mo. Bar No. [######]

18. MISSOURI PRACTICE NOTES

• 2017 SB 43 reform — controlling on causes of action accruing on or after August 28, 2017. SB 43 transformed the MHRA from one of the most plaintiff-friendly state employment statutes to one closely tracking Title VII. Counsel must verify the date of accrual: pre-August 28, 2017 claims retain "contributing factor" causation and broader liability; post-effective-date claims are governed by the framework summarized in this template.

• "Motivating factor" causation standard. RSMo § 213.010(19) defines "motivating factor" as the protected status "actually played a role in the adverse action or decision and had a determinative influence on the adverse decision or action." This is functionally a but-for / determinative-influence test that displaces the Daugherty / Hill "contributing factor" line of cases. Missouri Approved Instruction MAI 38.01 was revised in 2018 to reflect this change.

• Employer threshold (6 employees). RSMo § 213.010(8). Lower than Title VII's 15-employee threshold; do not assume both statutes apply.

• No individual supervisor liability under MHRA. RSMo § 213.010(8) excludes "any individual employed by an employer" from the definition of "employer." Pursue individual liability through 42 U.S.C. § 1981 (race), § 1983 (state actor), FMLA, or common-law tort theories where supported.

• Tiered damages caps (RSMo § 213.111.4). $50K (5–100 ee), $100K (101–200), $200K (201–500), $500K (500+). Caps apply to the SUM of compensatory and punitive damages and EXCLUDE back pay, interest on back pay, front pay, and equitable relief. Caps do not apply to parallel § 1981 claims.

• Codified business-judgment rule. RSMo § 213.101.4. The trier of fact "shall consider" any business judgment offered by the employer. This codifies the federal McDonnell Douglas burden-shifting framework and the bar on second-guessing reasoned business decisions absent evidence of pretext.

• Whistleblower's Protection Act (RSMo § 285.575). SB 43 also created the WPA, which is the EXCLUSIVE remedy for whistleblower retaliation against private-sector employers in Missouri (preempting common-law public-policy wrongful-discharge claims).

• Sex stereotyping under MHRA. The MHRA does not enumerate sexual orientation or gender identity as protected classes. However, Lampley v. Mo. Comm'n on Human Rights, 570 S.W.3d 16 (Mo. banc 2019), and R.M.A. v. Blue Springs R-IV, 568 S.W.3d 420 (Mo. banc 2019), recognize sex-stereotyping claims under "sex." Plead sex-stereotyping facts where applicable; pair with Title VII / Bostock for federal protection.

• 180-day MCHR filing deadline. RSMo § 213.075.1. Strict and may be raised "at any time" as a complete defense. Farrow v. St. Francis Med. Ctr., 407 S.W.3d 579 (Mo. banc 2013) (no equitable tolling).

• 90-day suit window post right-to-sue. RSMo § 213.111.1. Outer limit is 2 years from the alleged cause; failure to obtain a timely right-to-sue letter is fatal.

• Mo. R. Civ. P. 55 fact pleading. Missouri is a fact-pleading jurisdiction (Mo. R. Civ. P. 55.05). Plead specific facts supporting each element; conclusory allegations are vulnerable to motion to dismiss under Rule 55.27(a)(6).

• Removal exposure. Defendant may remove to U.S. District Court (Eastern or Western District of Missouri) on federal-question grounds where parallel federal counts are pleaded. Counsel must weigh forum selection against the inclusion of federal counts.

• Punitive-damages standard. Missouri requires "clear and convincing evidence" of evil motive or reckless indifference for punitive damages (Burnett v. Griffith, 769 S.W.2d 780 (Mo. banc 1989), as modified by RSMo § 510.261). Plead specific facts.

• Settlement and conciliation. Many Missouri MHRA cases resolve at MCHR mediation or in early circuit-court mediation. Local rules in Greene, Jackson, St. Louis City, and St. Louis County circuits have aggressive ADR provisions.

• Verification. Verification is not strictly required for civil petitions in Missouri (Mo. R. Civ. P. 55.03); however, some circuits have local rules and certain claims (e.g., post-judgment relief) do require sworn pleading. Verify local rule.

• Statute of limitations on parallel federal counts. Title VII / ADA: 90 days post-EEOC right-to-sue. ADEA: 90 days. § 1981: 4 years (28 U.S.C. § 1658) — significantly longer than MHRA's 2-year outer limit.

19. SOURCES AND REFERENCES

• Missouri Human Rights Act, RSMo Chapter 213 — https://revisor.mo.gov/main/OneChapter.aspx?chapter=213
• RSMo § 213.010 (Definitions) — https://revisor.mo.gov/main/OneSection.aspx?section=213.010
• RSMo § 213.055 (Unlawful employment practices) — https://revisor.mo.gov/main/OneSection.aspx?section=213.055
• RSMo § 213.065 (Public accommodations) — https://revisor.mo.gov/main/OneSection.aspx?section=213.065
• RSMo § 213.070 (Aiding, abetting, retaliation) — https://revisor.mo.gov/main/OneSection.aspx?section=213.070
• RSMo § 213.075 (Filing complaints with MCHR) — https://revisor.mo.gov/main/OneSection.aspx?section=213.075
• RSMo § 213.111 (Civil action; damages caps; jury trial) — https://revisor.mo.gov/main/OneSection.aspx?section=213.111
• Missouri SB 43 (2017) — https://www.senate.mo.gov/17info/BTS_Web/Bill.aspx?SessionType=R&BillID=56625879
• Missouri Approved Instructions — MAI 38.01(A) [2018 Revision] — https://www.courts.mo.gov/file.jsp?id=125834
• Missouri Commission on Human Rights — https://labor.mo.gov/mohumanrights
• MCHR Complaint Process — https://labor.mo.gov/mohumanrights/Complaint_Process
• U.S. Equal Employment Opportunity Commission — https://www.eeoc.gov/
• EEOC St. Louis District Office — https://www.eeoc.gov/field-office/stlouis/location
• EEOC Kansas City Area Office — https://www.eeoc.gov/field-office/kansascity/location
• Bostock v. Clayton County, 590 U.S. 644 (2020) (Title VII sex includes orientation and gender identity)
• Lampley v. Mo. Comm'n on Human Rights, 570 S.W.3d 16 (Mo. banc 2019) (sex stereotyping under MHRA)
• R.M.A. v. Blue Springs R-IV School Dist., 568 S.W.3d 420 (Mo. banc 2019) (transgender student sex-discrimination claim)
• Farrow v. St. Francis Med. Ctr., 407 S.W.3d 579 (Mo. banc 2013) (180-day deadline; jurisdictional)
• Daugherty v. City of Maryland Heights, 231 S.W.3d 814 (Mo. banc 2007) (pre-SB 43 contributing-factor standard — superseded by statute)
• Templemire v. W & M Welding, Inc., 433 S.W.3d 371 (Mo. banc 2014) (workers' comp retaliation; pre-SB 43)
• Yellow Freight Sys., Inc. v. Donnelly, 494 U.S. 820 (1990) (concurrent state-court jurisdiction over Title VII)
• Jones v. R.R. Donnelley & Sons, 541 U.S. 369 (2004) (4-year SOL for § 1981 employment claims)
• Mo. R. Civ. P. 55 (Pleadings) — https://www.courts.mo.gov/courts/ClerkHandbooksP2RulesOnly.nsf/c0c6ffa99df4993f86256ba50057dcb8/49b07d5f37e95b6986256ca60052139b
• Title VII, 42 U.S.C. § 2000e et seq. — https://www.eeoc.gov/statutes/title-vii-civil-rights-act-1964
• 42 U.S.C. § 1981 — https://www.law.cornell.edu/uscode/text/42/1981
• 42 U.S.C. § 1981a (federal damages caps) — https://www.law.cornell.edu/uscode/text/42/1981a
• ADEA, 29 U.S.C. § 621 et seq. — https://www.eeoc.gov/statutes/age-discrimination-employment-act-1967
• ADA, 42 U.S.C. § 12101 et seq. — https://www.ada.gov/

Disclaimer: This template is provided for informational purposes only and does not constitute legal advice. An attorney licensed in Missouri must review and customize this Petition before filing. The Missouri Human Rights Act was substantially amended by SB 43 (effective August 28, 2017); causation standards, damages caps, and individual liability rules differ from pre-2017 law. Verify all authorities and the date of accrual before filing.