Employee handbooks. The state Supreme Court has ruled that an employer's issuance of an employee handbook does not create an employment contract (Johnson v. McDonnell Douglas Corp., 745 S.W.2d 661 (1988)). Thus, Missouri courts have been very conservative in finding implied contracts based on employer policies and statements.
Nonetheless, if an employer has instituted a progressive discipline policy, it should follow it. Inconsistent discipline, especially when there is a discipline policy, can lead to claims of discrimination and unfair treatment.
For instance, a Missouri court of appeals held that an employer discriminated against a female employee by disciplining her more harshly than a similarly situated male employee for the same incident (Buchheit v. Missouri Commission on Human Rights, 215 S.W.3d 268 (2007)).
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