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Keywords

lawsuitappealpleamotiondiscriminationhuman rightsmotion to dismiss
plaintiffdefendantappealdiscriminationhuman rights

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R.M.A. by Appleberry v. Blue Springs R-IV School District, 568 S.W.3d 420, 364 Ed. Law Rep. 670

Facts

R.M.A., a female-to-male transgender student, filed a lawsuit against the Blue Springs R-IV School District and the School Board, claiming discrimination based on his sex. He alleged that he was denied access to boys' restrooms and locker rooms, which he argued constituted a violation of the Missouri Human Rights Act (MHRA). The Circuit Court dismissed his petition, prompting R.M.A. to appeal the decision. The case raised significant questions about the interpretation of sex discrimination under the MHRA, particularly in relation to transgender individuals.

R.M.A. alleged he 'is a female to male transgender teenager who was born as a female child and transitioned to living as male' while in the fourth grade. R.M.A. alleged Defendants unlawfully discriminated 'based on his sex.' Specifically, R.M.A. alleged Defendants prevented him from using the boys' restrooms and locker room because he 'is transgender and is alleged to have female genitalia.'

Issue

Did the Circuit Court err in dismissing R.M.A.'s petition alleging sex discrimination under the Missouri Human Rights Act?

Did the Circuit Court err in dismissing R.M.A.'s petition alleging sex discrimination under the Missouri Human Rights Act?

Rule

Analysis

The court analyzed whether R.M.A.'s allegations met the elements required for a sex discrimination claim under the MHRA. It found that R.M.A. adequately alleged that he was denied full and equal use of public accommodations, that he was a member of a protected class, and that his sex was a contributing factor in the denial of access to the boys' restrooms and locker rooms. The court emphasized that all properly pleaded facts must be accepted as true when reviewing a motion to dismiss.

R.M.A. asserts he has stated a claim under section 213.065.2, which, in relevant part, provides: 'It is an unlawful discriminatory practice for any person, directly or indirectly, to refuse, withhold from or deny any other person … advantages, facilities, services, or privileges made available in any place of public accommodation … or to segregate or discriminate against any such person in the use thereof on the grounds of … sex….' Therefore, the elements of a public accommodation sex discrimination claim under section 213.065 are: (1) plaintiff is a member of a class protected by section 213.065; (2) plaintiff was discriminated against in the use of a public accommodation (as defined by section 213.010); and (3) plaintiff's status as a member of a protected class was a contributing factor in that discrimination.

Conclusion

The Supreme Court vacated the Circuit Court's judgment and remanded the case for further proceedings, concluding that R.M.A. had sufficiently alleged a claim of sex discrimination under the MHRA.

For the reasons set forth above, the judgment of the circuit court is vacated, and the case is remanded to the circuit court for further proceedings.

Who won?

R.M.A. prevailed in the appeal as the Supreme Court found that he had adequately alleged the necessary elements of a sex discrimination claim under the Missouri Human Rights Act. The court's decision emphasized the importance of accepting all properly pleaded facts as true and highlighted the need for further proceedings to address the merits of R.M.A.'s claims.

R.M.A. prevailed in the appeal as the Supreme Court found that he had adequately alleged the necessary elements of a sex discrimination claim under the Missouri Human Rights Act.

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