Mo. Rev. Stat. » Chapter 213
Missouri Revised Statutes

Mo. Rev. Stat. § 213.070 (2026)

Additional unlawful discriminatory practices

✓ current as of May 2026
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  213.070.  Additional unlawful discriminatory practices. — 1.  It shall be an unlawful discriminatory practice for an employer, employment agency, labor organization, or place of public accommodation:

  (1)  To aid, abet, incite, compel, or coerce the commission of acts prohibited under this chapter or to attempt to do so;

  (2)  To retaliate or discriminate in any manner against any other person because such person has opposed any practice prohibited by this chapter or because such person has filed a complaint, testified, assisted, or participated in any manner in any investigation, proceeding or hearing conducted pursuant to this chapter;

  (3)  For the state or any political subdivision of this state to discriminate on the basis of race, color, religion, national origin, sex, ancestry, age, as it relates to employment, disability, or familial status as it relates to housing; or

  (4)  To discriminate in any manner against any other person because of such person's association with any person protected by this chapter.

  2.  This chapter, in addition to chapter 285 and chapter 287, shall provide the exclusive remedy for any and all claims for injury or damages arising out of an employment relationship.

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(L. 1986 S.B. 513, A.L. 1992 H.B. 1619, A.L. 1998 S.B. 786, A.L. 2017 S.B. 43)

Notes of Decisions
Cited in 95 cases (33 in the last 5 years), 1991–2025 · leading case: Keeney v. Hereford Concrete Prods., Inc., 911 S.W.2d 622 (Mo. 1995).
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Keeney v. Hereford Concrete Prods., Inc., 911 S.W.2d 622 (Mo. 1995). · cites it 98× “Additionally, section 213.070 states: It shall be an unlawful discriminatory practice: (2) To retaliate or discriminate in any manner against any other person because such person has opposed any practice prohibited by this chapter or because such person has filed a complaint,…”
Harold Lampley & Rene Frost v. The Missouri Comm'n on Human Rights & Alisa Warren, 570 S.W.3d 16 (Mo. 2019). · cites it 12× “Under section 213.070, “It shall be an unlawful discriminatory practice … [t]o discriminate in any manner against any other person because of such person’s association with any person protected by this chapter.”
Timothy Walsh v. City of Kansas City, Missouri, 481 S.W.3d 97 (Mo. Ct. App. 2016). · cites it 8× “2 Under the fact's presented here, Walsh could establish a -case for retaliation by showing that: (1) he participated in an investigation'of alleged discriminatory activity prohibited by! Section 213.070; and (2) “as a direct result, he .”
State Ex Rel. Diehl v. O'MALLEY, 95 S.W.3d 82 (Mo. 2003). · cites it 8× “070 to the extent that the alleged violation of section 213.070 relates to or involves a violation of section 213.”
Hill v. Ford Motor Co., 277 S.W.3d 659 (Mo. 2009). · cites it 7× “More specifically, Ford argues that even though this Court rejected the argument in Daugherty that federal law as interpreted in McDonnell Douglas should govern Missouri courts’ interpretation of a Missouri statute (the MHRA), this Court now should hold that federal rather than…”
Est. of Overbey v. Chad Franklin Nat'l Auto Sales North, LLC, 361 S.W.3d 364 (Mo. 2012). · cites it 8× “070, to the extent that the alleged violation of section 213.070 relates to or involves a violation of section 213.”
Missouri Comm'n on Human Rights v. Red Dragon Restaurant, Inc., 991 S.W.2d 161 (Mo. Ct. App. 1999). · cites it 13× “1 On appeal, Red Dragon argues that associational discrimination as embodied in § 213.070, RSMo Supp.1992, was not effective when the discriminatory incident occurred in 1991, and that associational discrimination was not intended as a cause of action under §§ 213.”
State v. Mo. Comm'n On Human Rights, 561 S.W.3d 48 (Mo. Ct. App. 2018). · cites it 12× “Section 213.070 provides in relevant part that 1.”
McCrainey v. Kansas City Missouri Sch. Dist., 337 S.W.3d 746 (Mo. Ct. App. 2011). · cites it 5× “By providing a retaliation cause of action, section 213.070 of the MHRA encourages employees to report and oppose *754 potentially discriminatory conduct.”
Keeney v. Missouri High. & Transp. Comm'n, 70 S.W.3d 597 (Mo. Ct. App. 2002). · cites it 6× “Section 213.070 2 provides: It shall be an unlawful discriminatory practice: [[Image here]] (3) For the state or any political subdivision of this state to discriminate on the basis of race, color, religion, national origin, sex, ancestry, age, as it relates to employment,…”
Cooper v. Albacore Holdings, Inc., 204 S.W.3d 238 (Mo. Ct. App. 2006). · cites it 3× “Under the MHRA, it is an unlawful discriminatory practice “[t]o retaliate or discriminate in any manner against any other person because such person has opposed any practice prohibited by this chapter or because such person has filed a complaint.”
Charlotte Jean Kerr v. The Curators of the Univ. of Missouri, 512 S.W.3d 798 (Mo. Ct. App. 2016). · cites it 3× “Section 213.070(2), RSMo 2000, provides: “It shall be an unlawful discriminatory practice .”
Show all 95 citing cases →
— Mo. Rev. Stat. § 213.070(2) — 32 cases
Keeney v. Hereford Concrete Prods., Inc., 911 S.W.2d 622 (Mo. 1995). “Additionally, section 213.070 states: It shall be an unlawful discriminatory practice: (2) To retaliate or discriminate in any manner against any other person because such person has opposed any practice prohibited by this chapter or because such person has filed a complaint,…”
McCrainey v. Kansas City Missouri Sch. Dist., 337 S.W.3d 746 (Mo. Ct. App. 2011). “By providing a retaliation cause of action, section 213.070 of the MHRA encourages employees to report and oppose *754 potentially discriminatory conduct.”
Timothy Walsh v. City of Kansas City, Missouri, 481 S.W.3d 97 (Mo. Ct. App. 2016). “2 Under the fact's presented here, Walsh could establish a -case for retaliation by showing that: (1) he participated in an investigation'of alleged discriminatory activity prohibited by! Section 213.070; and (2) “as a direct result, he .”
Cooper v. Albacore Holdings, Inc., 204 S.W.3d 238 (Mo. Ct. App. 2006). “Under the MHRA, it is an unlawful discriminatory practice “[t]o retaliate or discriminate in any manner against any other person because such person has opposed any practice prohibited by this chapter or because such person has filed a complaint.”
Charlotte Jean Kerr v. The Curators of the Univ. of Missouri, 512 S.W.3d 798 (Mo. Ct. App. 2016). “Section 213.070(2), RSMo 2000, provides: “It shall be an unlawful discriminatory practice .”
— Mo. Rev. Stat. § 213.070(3) — 2 cases
State v. Mo. Comm'n On Human Rights, 561 S.W.3d 48 (Mo. Ct. App. 2018). “Section 213.070 provides in relevant part that 1.”
Gustafson v. Bi-State Dev. Agency, 361 F. Supp. 3d 917 (E.D. Mo. 2019).
— Mo. Rev. Stat. § 213.070(4) — 4 cases
Missouri Comm'n on Human Rights v. Red Dragon Restaurant, Inc., 991 S.W.2d 161 (Mo. Ct. App. 1999). “1 On appeal, Red Dragon argues that associational discrimination as embodied in § 213.070, RSMo Supp.1992, was not effective when the discriminatory incident occurred in 1991, and that associational discrimination was not intended as a cause of action under §§ 213.”
Francin v. Mosby, Inc., 248 S.W.3d 619 (Mo. Ct. App. 2008).
Johnson v. Lou Fusz Auto. Network, Inc., 519 S.W.3d 450 (Mo. Ct. App. 2017).
Wallace v. Comprehealth, Inc., 36 F. Supp. 2d 892 (E.D. Mo. 1998).
— Mo. Rev. Stat. § 213.070(8)(c) — 1 case
Robert L. Davis v. Walgreen Co. (Mo. Ct. App. 2019).
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