Lampley v. Missouri Commission on Human Rights
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The Supreme Court reversed the judgment of the circuit court granting summary judgment in favor of the Missouri Commission on Human Rights (Commission) on Appellants’ consolidated allegations of violations of the Missouri Human Rights Act (Act), Mo. Rev. Stat. 213.010 et seq., holding that the circuit court erred in finding that Appellants’ claims failed under Pittman v. Cook Paper Recycling Corp., 478 S.W.3d 479 (Mo. App. W.D. 2015).
Specifically, the circuit court relied upon Pittman’s holding that the Act does not include claims for sex discrimination based upon sexual orientation and then extended that rationale to include claims for sex discrimination based upon sex stereotyping. The Supreme Court reversed and remanded the case, holding (1) the Commission improperly characterized Appellants’ claims as sexual orientation discrimination, and therefore, the circuit court’s reliance on Pittman was misplaced; and (2) the circuit court erred in issuing summary judgment in favor of Defendant because the Act covers sex discrimination.
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