The Missouri Supreme Court dismissed an appeal Tuesday in a discrimination case involving the estate of a deceased Missouri Department of Corrections employee, ruling that the lower court's judgment was incomplete and therefore not appealable.
In *Carter v. Missouri Department of Corrections* (Mo. 2025), the high court addressed cross-appeals from both Catharine Sue Carter, personal representative of the estate of David Carter, and the Missouri Department of Corrections following a jury verdict in Carter's favor on discrimination claims.
The case stems from David Carter's employment with the Missouri Department of Corrections beginning in May 2017, when he was 61 years old. According to court records, Carter was diagnosed with shingles in 2018, which became a focal point for workplace harassment.
The evidence, viewed in the light most favorable to the jury verdict, showed that Carter's supervisor repeatedly made disparaging comments about Carter to other employees and in front of inmates. The supervisor specifically targeted comments regarding Carter's shingles diagnosis and his age, while preventing Carter from accessing the tools and training required to perform his duties effectively.
The court found that the varying forms of harassment exacerbated Carter's condition, though the full extent of the workplace conduct was not detailed in the available opinion excerpt.
Following a jury trial in the Circuit Court of Jackson County before Judge Marty W. Seaton, Carter obtained a favorable verdict on his discrimination claims against the department. However, the circuit court's amended judgment reduced the damages pursuant to the damages cap established in Missouri Revised Statutes section 213.111.4.
Carter's estate challenged this reduction on multiple grounds. The estate argued that the circuit court's amended judgment reducing damages must be vacated as void. In the alternative, Carter's representatives contended that the statutory damages cap itself violates various constitutional provisions, though the specific constitutional challenges were not detailed in the available portion of the opinion.
The Missouri Department of Corrections mounted its own appeal, arguing that Carter failed to make a submissible case for discrimination under Missouri law. The department also contested the circuit court's decision to apply a multiplier to the attorney fees award, suggesting the court exceeded its authority in calculating the final fee award.
However, the Missouri Supreme Court declined to reach the merits of either party's arguments. Instead, the court found that the circuit court's judgment was not final because it failed to rule on Carter's requested equitable relief and his request for prejudgment interest.
Under Missouri law, an appeal can only proceed from a final judgment that resolves all claims and issues in the case. The court's finding that the judgment was incomplete meant that neither party could properly appeal at this time.
The dismissal represents a procedural victory for neither side, as it leaves the substantive questions unresolved. The constitutional challenge to Missouri's discrimination damages cap remains pending, as does the department's challenge to the underlying discrimination verdict.
The case highlights ongoing tensions between state employment discrimination laws and constitutional protections. Missouri's damages cap limits the amount plaintiffs can recover in discrimination cases, a provision that has faced constitutional challenges in various contexts.
The dismissal also underscores the importance of obtaining complete judgments before pursuing appeals. Courts cannot review incomplete judgments, even when both parties are eager to resolve substantive legal questions.
The opinion, originally issued Aug. 12, 2025, was modified by the court on its own motion Sept. 9, 2025, though the nature of the modification was not specified in the available materials.
With the appeal dismissed, the case returns to the Jackson County Circuit Court, where Judge Seaton must address the remaining issues of equitable relief and prejudgment interest before any final judgment can be entered.
The Missouri Department of Corrections will need to await resolution of these remaining issues before it can challenge the discrimination verdict or attorney fee award. Similarly, Carter's estate must wait to pursue its constitutional challenge to the damages cap.
The case serves as a reminder that employment discrimination cases can involve complex procedural hurdles even after successful jury verdicts. The intersection of state damages caps with constitutional protections remains an area of active litigation across multiple jurisdictions.
For now, both parties must return to the circuit court to complete the proceedings before any appellate review can occur.