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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