Robinson v. COURTYARD MANAGEMENT CORP.
329 S.W.3d 736
Mo. Ct. App.2011Background
- Robinson, a front-desk clerk, sustained a knee injury, returned to light duty in June and full duty in July 2009, with the hotel budget reducing or modifying duties.
- New duties required more standing and walking after full-duty return, potentially increasing physical strain on Robinson's knee.
- Robinson submitted a medical note on August 31, 2009, recommending restrictions; employer indicated it could accommodate restrictions.
- Robinson left notes and failed to report for multiple shifts beginning September 1, 2009, and did not respond to employer accommodations or inquiries.
- Employer discharged Robinson on September 10, 2009 for abandoning her job after missing several shifts.
- Lower tribunals concluded Robinson voluntarily quit; the court reversed, holding she was discharged for misconduct and remanded for modification consistent with the opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did Robinson voluntarily leave employment? | Robinson intended to return post-recovery. | Employer discharged for abandonment, not a voluntary quit. | Not a voluntary quit; discharge for misconduct affirmed on reconsideration. |
| Was Robinson discharged for misconduct? | Missed shifts due to medical reasons and accommodation attempts negate misconduct. | Repeatedly failing to report and respond to accommodations constituted misconduct. | Discharged for misconduct; willful disregard of employer's rules. |
| Did Robinson request medical leave? | Follow doctor’s orders; may imply medical leave. | Records show doctor released to work with restrictions; no leave request substantiated. | No valid medical-leave request supported by record. |
Key Cases Cited
- Noah v. Lindbergh Inv., LLC, 320 S.W.3d 212 (Mo.App. E.D.2010) (strict, narrow construction of voluntary-quit provisions; misconduct analysis)
- Dameron v. Drury Inns, Inc., 190 S.W.3d 508 (Mo.App. E.D.2006) (work-related misconduct requires willful violation; burden on employer)
