Dwight Tuttle v. Dobbs Tire & Auto Centers, Inc., David Dobbs, and Dustin Dobbs, 590 S.W.3d 307

Dobbs Tire & Auto Centers is a Missouri corporation with headquarters in Jefferson County; Tuttle worked for Dobbs Tire from 1989–2017 and managed the Shiloh, Illinois store from 2003–2016 (later transferred to another Illinois store).
Tuttle alleged age discrimination and retaliation beginning in 2015: withheld raises, improper expense allocations to his store, a transfer to a lower‑volume Illinois store, a transfer agreement exposing him to termination, disparate treatment of younger managers, and an insinuation to get his resume; he resigned March 13, 2017 (constructive discharge).
Tuttle filed an MCHR charge and obtained a right‑to‑sue letter (Oct. 16, 2017), then sued in St. Louis County under the MHRA for age discrimination (§213.055) and retaliation (§213.070).
Dobbs moved to dismiss, arguing the MHRA does not apply to alleged discriminatory acts and adverse impacts that occurred in Illinois; the circuit court dismissed with prejudice, the court of appeals affirmed, and the Supreme Court of Missouri granted transfer.
Holding: Because Tuttle alleged the actionable adverse impacts (loss of wages/benefits and mental anguish from constructive discharge) occurred in Illinois, and the MHRA contains no express extraterritorial application, the presumption against extraterritoriality precludes applying the MHRA to his claims; the dismissal was affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the MHRA applies when alleged discriminatory decisions originate in Missouri but the adverse impacts occur in another state	Tuttle argued some discriminatory decisions were made at Missouri headquarters, so MHRA applies	Dobbs argued the alleged adverse impacts and unlawful acts occurred in Illinois, and MHRA does not apply extraterritorially	Court held MHRA does not apply because actionable adverse impact occurred in Illinois and MHRA has no express extraterritorial reach
Whether Tuttle sufficiently pleaded he was "aggrieved" within Missouri for MHRA jurisdiction	Tuttle claimed "one or more" discriminatory decisions/actions occurred in Missouri and alleged facts supporting discriminatory treatment	Dobbs argued Tuttle failed to plead any aggrieving adverse impact in Missouri and thus failed to state a claim	Court held plaintiff must be aggrieved by an unlawful discriminatory practice in Missouri; here the aggrievement (losses and constructive discharge) occurred in Illinois, so claim fails

Kader v. Bd. of Regents of Harris‑Stowe State Univ., 565 S.W.3d 182 (Mo. banc 2019) (MHRA prohibits unlawful employment discrimination and requires an actionable adverse impact on the plaintiff).
Cope v. Parson, 570 S.W.3d 579 (Mo. banc 2019) (motion to dismiss for failure to state a claim is reviewed de novo; factual allegations taken as true).
Rositzky v. Rositzky, 46 S.W.2d 591 (Mo. 1931) (longstanding presumption that state statutes do not have extraterritorial effect absent clear legislative intent).
Igoe v. Dep’t of Labor & Indus. Relations of Missouri, 152 S.W.3d 284 (Mo. banc 2005) (location of employer decision‑making is relevant to venue questions under the MHRA).
Morrison v. Nat’l Australia Bank Ltd., 561 U.S. 247 (U.S. 2010) (recognizes presumption against extraterritorial application of statutes).