Woodruff v. Jefferson City Area Young Men's Christian Association, 2:17-cv-04244

Plaintiff Kathlene Woodruff worked for the Jefferson City YMCA from April 2008 until her termination in July 2016 and took approved medical leave Nov 2015–Jan 2016.
After returning, Woodruff alleges retaliatory treatment (written/verbal warnings, poor evaluations, discipline, and eventual termination) for exercising FMLA rights and alleges disability discrimination under the Missouri Human Rights Act (MHRA).
Defendants include the YMCA and individual employees: CEO Craig Lammers, supervisor Michelle Poire, and finance director Kathleen Frese; Lammers and Poire moved to dismiss under Rule 12(b)(6).
Lammers and Poire sought dismissal of claims against them in their official capacities as redundant to suit against the YMCA and argued the MHRA’s 2017 amendment eliminating individual liability precludes Count II against them individually.
Plaintiff did not oppose dismissal of official-capacity claims but argued the MHRA amendment is not retroactive (and thus does not bar individual liability) and asserted an ex post facto concern if applied retroactively.
The court granted dismissal of official-capacity claims as redundant and denied dismissal of Count II against Lammers and Poire in their individual capacities, finding the 2017 MHRA amendment substantive and not retroactive.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether official-capacity claims against Lammers and Poire are redundant	Woodruff did not oppose; conceded redundancy	Official-capacity claims duplicate suit against the YMCA	Granted — official-capacity claims dismissed as redundant
Whether individual liability under the MHRA was abrogated for claims arising before the 2017 amendment	Woodruff: 2017 amendment is not retroactive; individual liability remains; retroactive application would violate Art I §13	Lammers/Poire: 2017 amendment excludes individuals from employer definition; amendment applies	Denied — amendment is substantive and not retroactive; individual MHRA claims survive

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (established plausibility standard for complaints)
Ashcroft v. Iqbal, 556 U.S. 662 (clarified Twombly and permissible judicial inferences at pleadings stage)
Artis v. Francis Howell North Band Booster Ass’n, 161 F.3d 1178 (official-capacity suit is equivalent to suit against the entity)
Carton v. General Motor Acceptance Corp., 611 F.3d 451 (complaint construed in favor of nonmoving party on 12(b)(6))
Mills v. City of Grand Forks, 614 F.3d 495 (materials properly considered on 12(b)(6))
Porous Media Corp. v. Pall Corp., 186 F.3d 1077 (same)
Klotz v. St. Anthony’s Med. Ctr., 311 S.W.3d 752 (Mo. banc) (legislature cannot change substantive rights after cause of action accrues)
Hess v. Chase Manhattan Bank, USA, N.A., 220 S.W.3d 758 (Mo. banc) (distinguishing substantive vs. procedural/remedial statutes)
City of Harrisonville v. McCall Serv. Stations, 495 S.W.3d 738 (Mo. banc) (retroactive statutory changes to damages barred as retrospective)