The Missouri Supreme Court dismissed an appeal in *Kevin Rhodes v. Missouri Highways and Transportation Commission* (Mo. 2025), ruling that the judgment was not final because it failed to address the plaintiff's request for equitable relief and prejudgment interest.

Rhodes, a former employee of the Missouri Highways and Transportation Commission, had won a jury verdict in Jackson County Circuit Court on claims for hostile work environment and retaliation under the Missouri Human Rights Act. The case centered on events during Rhodes's final year of employment in 2019, when he was accused of using a racial slur and subsequently investigated by the commission.

According to court documents, Rhodes began working for the commission in 2001 and was terminated in December 2019. During the investigation into the racial slur allegation, Rhodes filed grievances regarding his treatment by supervisors. The investigation ultimately substantiated not only the racial slur allegation but also other allegations of workplace misconduct, leading to Rhodes's suspension and eventual termination.

Following his termination, Rhodes filed two charges of discrimination with the Missouri Commission on Human Rights. He then pursued litigation in circuit court, where a jury found in his favor on his hostile work environment and retaliation claims under the Missouri Human Rights Act.

The case reached the Missouri Supreme Court when both parties appealed different aspects of the circuit court's judgment. Rhodes challenged the constitutional validity of the damages cap found in section 213.111.4 of the Missouri Human Rights Act. His constitutional challenge was comprehensive, arguing that the damages cap violated multiple provisions of the Missouri Constitution, including his right to a jury trial, equal protection guarantees, due process rights, the separation of powers mandate, and the open court provision.

The Missouri Highways and Transportation Commission filed a cross-appeal, arguing that Rhodes had failed to make a submissible case for his hostile work environment and retaliation claims. The commission sought to overturn the jury verdict entirely.

However, the Missouri Supreme Court declined to reach the merits of either party's arguments. In its opinion issued August 12, 2025, and modified September 9, 2025, the court found that the circuit court's judgment was not final because it failed to rule on Rhodes's requests for equitable relief and prejudgment interest.

Under Missouri procedural rules, an appeal can only be taken from a final judgment that resolves all claims and issues in a case. Because the circuit court had not addressed all aspects of Rhodes's requested relief, the Supreme Court determined it lacked jurisdiction to hear the appeal.

The dismissal means that Rhodes's constitutional challenge to the Missouri Human Rights Act's damages cap remains unresolved. The damages cap provision limits the amount of compensation that can be awarded to victims of employment discrimination, and Rhodes's challenge could have significant implications for future discrimination cases if it were to succeed.

The case highlights ongoing tensions between statutory damages caps and constitutional protections for jury trial rights. Similar challenges to damages caps have been raised in other jurisdictions, with varying results. Some courts have found that caps impermissibly interfere with the jury's role in determining appropriate compensation, while others have upheld them as legitimate legislative policy choices.

Rhodes's constitutional arguments were particularly broad, encompassing multiple theories for why the damages cap should be struck down. His jury trial argument likely centered on the principle that caps interfere with the jury's traditional role in determining damages. The equal protection claim may have focused on how caps treat discrimination victims differently from other tort victims. Due process arguments typically challenge whether caps are arbitrary or bear no rational relationship to legitimate government interests.

The separation of powers challenge would argue that damages caps represent improper legislative interference with judicial functions, while the open court provision argument would contend that caps violate constitutional guarantees of access to courts and adequate remedies.

With the appeal dismissed, the case will return to the Jackson County Circuit Court to resolve the outstanding issues regarding equitable relief and prejudgment interest. Once those matters are addressed and a final judgment is entered, either party could potentially appeal again to the Missouri Supreme Court.

The dismissal also means that the commission's challenge to the sufficiency of Rhodes's evidence remains unresolved. The commission will need to wait for a final judgment before it can pursue its argument that Rhodes failed to prove his hostile work environment and retaliation claims.

For employment law practitioners and discrimination victims in Missouri, the case represents a missed opportunity for clarity on the constitutional status of damages caps under the Missouri Human Rights Act. The constitutional questions raised by Rhodes will likely continue to arise in future cases until they are definitively resolved by the state's highest court.