“The Rhodes Rule”: Missouri Supreme Court Re-Affirms that an Order Is Not Appealable Unless Every Requested Remedy—Legal and Equitable—Is Expressly Resolved

1. Introduction

Kevin Rhodes, a former employee of the Missouri Highways and Transportation Commission (“the Commission”), sued his employer for hostile work environment and retaliation under the Missouri Human Rights Act (MHRA) after being terminated in 2019. A Jackson County jury awarded Rhodes more than $1.9 million. The trial judge, applying the statutory cap in §213.111.4, reduced the award to back pay of $24,997 plus a lump-sum $500,000 for all other damages. Both sides appealed: Rhodes challenged the constitutionality of the damages cap, while the Commission contended that Rhodes had not made a submissible case at trial.

Before reaching those substantive questions, however, the Supreme Court of Missouri—sitting en banc—found a jurisdictional defect: the trial court never ruled on Rhodes’s requests for equitable relief (front pay/reinstatement) and pre-judgment interest. Because those requests remained pending, the judgment was not “final” under Missouri’s “complete disposition” doctrine, and the Court dismissed the appeal.

2. Summary of the Judgment

The Court reiterated that a statutory right to appeal exists only after entry of a final judgment that disposes of all claims and requested remedies.
The circuit court’s written judgment omitted any reference to (i) equitable relief (reinstatement/front pay) and (ii) prejudgment interest, both expressly sought in every count.
Because at least one form of relief was left undecided, no final judgment existed; therefore, the Supreme Court lacked appellate jurisdiction and dismissed the appeal.
Result: Neither the constitutional attack on the MHRA damages cap nor the sufficiency of the evidence was addressed on the merits.

3. Analysis

3.1 Precedents Cited and Their Influence

Anderson v. Metcalf, 300 S.W.2d 377 (Mo. 1957) – Recognized that the right of appeal is purely statutory, laying groundwork for the Court’s jurisdictional inquiry in every case.
Gibson v. Brewer, 952 S.W.2d 239 (Mo. banc 1997) – Reiterated the rule that a prerequisite to appellate review is a final judgment.
Jefferson County 9-1-1 Dispatch v. Plaggenberg, 645 S.W.3d 473 (Mo. banc 2022) – Defined a final judgment as one disposing of all claims (or the last pending claim); heavily quoted by the Court.
Wilson v. City of St. Louis, 600 S.W.3d 763 (Mo. banc 2020) – Clarified that even when a pleading seeks multiple remedies, if they arise from one set of facts they constitute one claim, and partial disposition is insufficient.
Committee for Educational Equality v. State, 878 S.W.2d 446 (Mo. banc 1994) – Introduced the “aggregate of operative facts” test for identifying separate claims; cited for distinguishing claims from remedies.
State ex rel. Barker v. Tobben, 311 S.W.3d 798 (Mo. banc 2010) and State ex rel. Leonardi v. Sherry, 137 S.W.3d 462 (Mo. banc 2004) – Explain that in mixed law/equity cases the jury decides legal issues first, with the court then determining equitable relief.
Boley v. Knowles, 905 S.W.2d 86 (Mo. banc 1995) – Holds that appellate courts must independently verify their jurisdiction even if the parties do not raise the issue.

3.2 Legal Reasoning of the Court

The Court’s reasoning followed a structured path:

Statutory Basis for Appeal (§512.020 RSMo).
Appeals exist only where authorized by statute; §512.020(5) permits appeal from a “final judgment”.
Definition of “Final Judgment”.
Drawing on Plaggenberg, Wilson, and CEE, the Court reaffirmed that a judgment is final only if it disposes of every claim or remedy stemming from the operative facts. The focus is on rights and remedies, not merely on the number of counts in a petition.
Examination of the Circuit-Court Judgment.
The written judgment awarded (i) actual/compensatory damages, (ii) reduced punitive damages, (iii) attorney’s fees, costs, and (iv) post-judgment interest. It was silent on (a) pre-judgment interest and (b) equitable relief (front pay/reinstatement). No catch-all “all other relief denied” language appeared.
Effect of Omitted Relief.
Because the pleadings expressly requested front pay and prejudgment interest, those matters remained “open for further adjudication.” Under Wilson, partial resolution cannot create finality.
Resulting Lack of Appellate Jurisdiction.
Without a final judgment, the Supreme Court lacked power to hear the constitutional challenge or the Commission’s cross-appeal; dismissal was mandatory under Boley v. Knowles.

3.3 Anticipated Impact of the Decision

Procedural Vigilance for Practitioners. Trial counsel must ensure that judgments explicitly resolve every requested remedy (even if theoretically moot after a jury verdict) or contain language denying residual relief. Failing to do so can result in dismissal months or years later, wasting judicial and party resources.
Trial-Court Drafting and Boilerplate. Judges may adopt “all relief not expressly granted is denied” boilerplate to forestall similar jurisdictional pitfalls.
Delayed Constitutional Clarity. The eagerly watched challenge to §213.111.4’s damages cap will have to wait. Employers, employees, and insurers wanting guidance on the cap’s constitutionality remain in limbo.
Re-emphasis on the Law/Equity Sequencing Rule. The decision reinforces that equitable components—front pay, reinstatement, rescission, declarations—are tried to the court, after the jury, and must be resolved in writing.

4. Complex Concepts Simplified

Final Judgment: A written order that decides everything the plaintiff asked for (or expressly denies it), so nothing is left for the trial court to do. Only then may the losing party appeal.
Mixed Law and Equity Case: A lawsuit containing both (i) claims that carry a right to a jury (legal claims) and (ii) requests that a judge must decide, such as injunctions or reinstatement (equitable relief).
Front Pay: Monetary award meant to compensate a wrongfully terminated employee for future lost wages in lieu of reinstatement.
Pre-judgment Interest: Interest that accrues on a money award from the date the claim arose until judgment is entered, as opposed to post-judgment interest, which accrues after entry of judgment.
Submissible Case: A case with sufficient evidence on each required element to justify sending it to the jury.
Damages Cap (§213.111.4): A statutory ceiling on the amount of compensatory and punitive damages a plaintiff may recover under the MHRA, tied to employer size.

5. Conclusion

In Rhodes v. Missouri Highways & Transportation Commission, the Supreme Court of Missouri did not interpret the MHRA damages cap, nor did it weigh the sufficiency of the evidence. Instead, it elevated procedure over substance, reminding litigants of a foundational jurisdictional command: no appeal lies until the trial court has finally disposed of every requested remedy—legal or equitable. This “Rhodes Rule” is not new, but the Court’s emphatic re-statement after a multi-million-dollar jury verdict and a high-profile constitutional challenge gives the principle renewed force. Future litigants should scrutinize draft judgments for completeness; otherwise, even the most consequential legal issues will remain unanswered while the parties are sent back to square one.