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Diaz v. AutoZoners, LLC, d/b/a AutoZone, et al., No. WD77861 (Mo. Ct. App. Nov. 10, 2015)

Articles Discussing Case:

Missouri Appeals Court Addresses Third Party Harassment Claim Against Parent Company

XpertHR • November 23, 2015
A Missouri appeals court has declined to find a parent company liable for the acts of its subsidiary under the state civil rights law. In Diaz v. AutoZoners, LLC, a case alleging third-party sexual harassment (i.e., an employee alleged being harassed by two customers), the Missouri Court of Appeals for the Western District reversed a jury verdict and judgments against the parent company.

Parent Company not ‘Employer’ under Missouri Law, Court Rules, Reverses $1.5 Million Award

Jackson Lewis P.C. • November 12, 2015
An employer’s parent corporation that did not “directly act[] in the interest” of the employer was not a covered employer under the Missouri Human Rights Act liable for harassment and retaliation, a Missouri Court of Appeals has ruled. Diaz v. AutoZoners, LLC, d/b/a AutoZone, et al., No. WD77861 (Mo. Ct. App. Nov. 10, 2015). The Court applied a modified “economic realities” test and reversed the jury verdict and judgment of $1,500,000 in punitive damages against the parent corporation.

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