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Robinson v. COURTYARD MANAGEMENT CORP.
329 S.W.3d 736
Mo. Ct. App.
2011
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Background

  • 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)
Read the full case

Case Details

Case Name: Robinson v. COURTYARD MANAGEMENT CORP.
Court Name: Missouri Court of Appeals
Date Published: Jan 11, 2011
Citation: 329 S.W.3d 736
Docket Number: ED 94800
Court Abbreviation: Mo. Ct. App.