Supreme Court of Missouri Affirms Ruling for Nearly $1M in Damages for Client Retaliated Against by Employer

White, Graham, Buckley & Carr partner Bryan White helped an employee secure nearly $1M in damages for the retaliation and discrimination he suffered at the hands of his employer following a work injury. The employer, Johnson Controls, Inc., appealed the trial court’s judgment and the amount of damages all the way up to the Supreme Court of Missouri. White successfully defended the judgment on appeal and the Supreme Court of Missouri affirmed the lower court’s ruling and judgment in all respects.

Filed in late 2021 in Gentry County (Missouri) Circuit Court, the lawsuit alleged Johnson Controls retaliated against a longtime employee after the employee suffered and reported a work injury. Johnson Controls’ in-house legal team ignored the lawsuit after it was served, leading to a default judgment on the employee’s claims. After hearing evidence on damages, the trial court entered a default judgment against the company, awarding the plaintiff $300,000 in compensatory damages and $600,000 in punitive damages.

Johnson Controls filed a motion asking the trial court to set the default judgment aside under Rules 74.05, 74.06 and 75.01, contending that the failure to answer was an excusable error and asserting it had a valid defense to the claims. The trial court denied the motion and refused to set aside the judgment. The company appealed to the Court of Appeals and for the first time also argued that the punitive damages should not have been awarded because a 2020 revision to Missouri’s statute on punitive damages did not allow Plaintiff to seek punitive damages in the initial lawsuit filing without getting permission from the trial court. Johnson Controls argued the punitive damage award was entered in error because the Plaintiff did not follow the statutory procedure. 

Arguing that the punitive damages were improperly awarded as part of the default judgment, the company asked for review of a “plain error.” The Court of Appeals rejected those arguments and affirmed the trial court’s judgment.

Johnson Controls then appealed to the Supreme Court of Missouri, which accepted the case. White again successfully defended the judgment on appeal. The Supreme Court clarified the applicable law, holding that Rules 74.06 and 75.01 could not be used to challenge default judgments, and further affirmed the trial court’s ruling refusing the set aside the judgment under Rule 74.05. The Supreme Court also found insufficient grounds to overturn the punitive damages award and upheld the initial ruling entirely, affirming the employee’s claims of retaliatory discharge and the award of damages.