Coyle v. City of St. Louis
408 S.W.3d 281
Mo. Ct. App.2013Background
- Plaintiff, African American, alleged race-based failure to promote him to fire chief in St. Louis Fire Department, after earlier demotion of Chief George and changes in city leadership.
- Chief George, demoted in 2007 for failing to make promotions, challenged the demotion; Civil Service Commission found no racial basis and Missouri Court of Appeals affirmed.
- Plaintiff applied for interim and permanent fire chief positions; white officials were chosen instead, leading to MHRA suit and trial.
- Before trial, Plaintiff sought to exclude from evidence the outcomes of George’s demotion appeal; the trial court allowed limited inquiry about George’s filing but excluded outcomes.
- At trial, Plaintiff elicited a limited question about George’s demotion appeal; the court instructed the jury to disregard after objections; verdict awarded $300,000 actual and $50,000 punitive damages to Plaintiff.
- Post-trial, Plaintiff sought equitable relief and attorneys’ fees; City sought mistrial and new trial relief due to alleged counsel misconduct and evidentiary rulings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Mistrial/new trial for misconduct | Coyle’s bias evidence was properly admitted; curative instructions cured prejudice. | Counsel's questioning violated the limine and prejudiced the jury; mistrial required. | Denied; curative instructions sufficed; no abuse of discretion. |
| Exclusion of outcomes of Chief George’s claim | Evidence of George’s claim outcomes was relevant to bias and completeness. | Outcomes were minimally probative and risked jury confusion; exclusion proper. | Exclusion affirmed; not materially affecting merits. |
| Attorneys’ fees on appeal | MHRA allows reasonable fees to prevailing party; fees on appeal warranted. | Appeals fees should be determined by trial court on remand. | Remand to determine reasonable appellate fees. |
| Equitable relief (front pay and retirement/promotion orders) | Front pay and equitable relief should make whole; promote to next fire chief position; retirement benefits may be warranted. | Front pay limited; retirement benefits not clearly authorized; no certain promotion feasible. | Remand for front pay calculation and further equitable relief; retirement benefits and promotion ordered on remand as appropriate. |
Key Cases Cited
- Dooley v. St Louis County, 302 S.W.3d 202 (Mo.App.E.D.2009) (mistrial standards; abuse of discretion review)
- In re Brasch, 332 S.W.3d 115 (Mo.banc 2011) (abuse of discretion; mistrial considerations)
- Ryan v. Campbell “66” Exp., Inc., 304 S.W.2d 825 (Mo.banc 1957) (willful misconduct and prejudicial impact; mistrial standard)
- Liszewski v. Union Elec. Co., 941 S.W.2d 748 (Mo.App.E.D.1997) (witness bias admissibility and litigation strategy)
- Brown v. Bailey, 210 S.W.3d 897 (Mo.App.E.D.2006) (curative measures for prejudicial testimony)
- Williams v. Trans States Airlines, 281 S.W.3d 854 (Mo.App.E.D.2009) (admissibility of similar incidents and completeness doctrine)
- Delacroix v. Doncasters, Inc., 407 S.W.3d 13 (Mo.App.E.D.2013) (evidence exclusion and prejudicial risk; appellate standard)
- Diehl v. O’Malley, 95 S.W.3d 82 (Mo.banc 2003) (mhra make-whole relief and remedies)
- Gilliland v. Mo. Athletic Club, 273 S.W.3d 516 (Mo.banc 2009) (attorney fees under MHRA; prevailing party)
- Outcam? (Outcom) v. City of Lake St. Louis, 960 S.W.2d 1 (Mo.App.E.D.1996) (remand when evidence needed for front pay equitable relief)
- Pollock v. Wetterati Food Distrib. Group, 11 S.W.3d 754 (Mo.App.E.D.1999) (attorneys’ fees; MHRA remedies)
- Williams v. Trans States Airlines, 281 S.W.3d 854 (Mo.App.E.D.2009) (evidence of similar incidents and prejudice)
- Brady v. Curators of Univ. of Mo., 213 S.W.3d 101 (Mo.App.E.D.2006) (front pay and retirement benefits in MHRA context)