Background
Amber Ledbetter, a white woman over forty, worked for Jackson County, Missouri for nearly twenty-six years, most recently as population control coordinator in the county jail. Beginning around 2018, after a new supervisor took over as director of corrections, Ledbetter alleged a pattern of discriminatory and retaliatory treatment: being excluded from meetings essential to her job, having her duties stripped, being blocked from communicating with courts, and facing general dismissiveness. She verbally complained to human resources on multiple occasions and, by sometime before July 2020, reported to the supervisor’s superior that she believed she was being retaliated against.
In July 2020, Ledbetter was placed on administrative leave following a Facebook post deemed racially insensitive and a whiteboard in her office bearing derogatory terms. In December 2020, her supervisor recommended she be demoted. Ledbetter resigned in January 2021, citing unfair treatment, a hostile environment, and fear of retaliation. She filed a charge with the Missouri Commission on Human Rights and, after receiving a right-to-sue letter, brought suit in circuit court alleging sex discrimination, age discrimination, race discrimination, retaliation, and hostile work environment under the Missouri Human Rights Act (MHRA).
The Jackson County Circuit Court granted summary judgment for the employer on all claims in May 2025 without stating its reasoning. Ledbetter appealed, raising fourteen points of error. All Jackson County circuit judges had recused, and a special judge was assigned by the Missouri Supreme Court.
The Court’s Holding
The Court of Appeals affirmed summary judgment on all claims arising from events before October 13, 2019, finding those claims time-barred under the MHRA’s two-year statute of limitations. Because Ledbetter failed on appeal to argue that the continuing-violation doctrine should preserve her pre-limitations claims, and because the circuit court’s unspecified grant of summary judgment is presumed to rest on the grounds raised in the employer’s motion — which included a limitations defense — the appellate court held she waived that argument. The court also affirmed summary judgment on the age discrimination claim, which Ledbetter conceded at oral argument.
However, the court reversed summary judgment on Ledbetter’s race discrimination, sex discrimination, retaliation, and hostile work environment claims to the extent those claims rest on events occurring after October 13, 2019. The court found that Jackson County’s responses to Ledbetter’s statement of uncontroverted material facts repeatedly failed to comply with Missouri Rule 74.04(c)(2) — many denials lacked any citation to the record or cited exhibits that were not before the court — causing those facts to be deemed admitted. Combined with the admitted facts and the confused, undated timeline in the summary judgment record, genuine issues of material fact precluded judgment as a matter of law on those claims.
The case is remanded to the circuit court for further proceedings on the surviving post-October 13, 2019 claims.
Key Takeaways
- An MHRA plaintiff who fails on appeal to argue the continuing-violation exception to the statute of limitations forfeits pre-limitations claims, even under de novo review — appellants always bear the burden of establishing error.
- Strict compliance with Missouri Rule 74.04(c)(2) is mandatory: a summary judgment movant’s bare denials or citations lacking specific page references are treated as admissions of the opposing party’s stated facts, which can defeat the motion.
- Summary judgment is rarely appropriate in employment discrimination cases; where the record viewed in the light most favorable to the non-movant presents two plausible but contradictory accounts of material facts, summary judgment must be denied.
- Age discrimination claims not challenged on appeal — here conceded at oral argument — remain finally adjudicated in favor of the employer.
Why It Matters
This decision serves as a pointed reminder to employment defense counsel that procedural shortcuts in summary judgment briefing carry real risk. Jackson County’s failure to properly cite the record when disputing Ledbetter’s facts resulted in those facts being deemed admitted, directly contributing to the reversal. For plaintiffs’ counsel, the case underscores the importance of expressly challenging every basis for summary judgment on appeal — including limitations defenses and the continuing-violation doctrine — because silence is treated as waiver even when the standard of review is de novo.
More broadly, the opinion reinforces Missouri’s long-standing rule that employment discrimination cases are ill-suited to summary judgment resolution. Where a supervisor’s treatment of an employee extends over years and the record is muddied by inconsistent dates and incomplete citations, courts will find genuine factual disputes that require a jury to resolve.