Sakaguchi v. Missouri Department of Corrections
2010 Mo. App. LEXIS 1694
| Mo. Ct. App. | 2010Background
- Sakaguchi, employed by Missouri Department of Corrections, was terminated April 22, 2009 for alleged misconduct.
- The sole issue found by the Commission was Sakaguchi’s failure to relocate her office from St. Joseph to Cameron, despite multiple directives.
- Her relocation was mandated due to business needs; she appealed the directive and initially complied only partially.
- The Commission concluded the partial non-move constituted misconduct connected with work and denied unemployment benefits.
- The Western District reversed the Commission, finding no willful disregard or misconduct, and remanded for further proceedings.
- This decision rests on statutory definitions of misconduct and the evidentiary standard for proving such misconduct.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Sakaguchi’s conduct misconduct connected with work? | Sakaguchi argues no willful disregard. | Employer contends failure to relocate shows misconduct. | No; not proven as willful misconduct; remand. |
Key Cases Cited
- Hoover v. Cmty. Blood Ctr., 153 S.W.3d 9 (Mo.App. W.D. 2005) (burden on employer to prove misconduct by preponderance; intent element)
- McClelland v. Hogan Pers., LLC, 116 S.W.3d 660 (Mo.App. W.D. 2003) (each misconduct criterion contains culpability element)
- Dixon v. Div. of Emp't Sec., 106 S.W.3d 536 (Mo.App. W.D. 2003) (willful misconduct requires intentional disregard)
- Dixon v. Stoam Indus., Inc., 216 S.W.3d 688 (Mo.App. S.D. 2007) (refusal to comply with lawful directive can be misconduct)
- Williams v. Enter. Rent-A-Car Shared Servs., LLC, 297 S.W.3d 139 (Mo.App. E.D. 2009) (willful disregards require conscious violation of rules)