Missouri Court of Appeals for the Western District in Kansas City
KANSAS CITY — The Missouri Court of Appeals Western District has upheld a lower court’s decision denying a former Missouri Department of Agriculture employee interest on a back-pay award, ruling that the Administrative Hearing Commission (AHC) lacked statutory authority to grant such interest.
The case was decided by a three-judge panel composed of Presiding Judge Gary D. Witt, Judge Alok Ahuja and Judge Karen King Mitchell, and the court affirmed the Nodaway Circuit Court’s judgment.
Stiens, who represented himself, argued that he was entitled to interest on back pay owed to him following a prior ruling that found his 2017 termination improper.
Stiens contended that the AHC should have awarded him interest because the back-pay award constituted liquidated damages under a Missouri statute, which provides for 9% annual interest when no other rate is specified.
He also argued that a prior circuit court judgment ordering back pay “with interest at the statutory rate” established the law of the case and that the Department of Agriculture was barred from contesting the interest issue since it had not appealed that judgment.
The appellate court rejected those arguments, concluding that the AHC was not authorized by law to award interest in such cases.
Writing for the panel, Mitchell explained that the AHC is a “creature of statute,” and therefore its authority is strictly limited to what the legislature provides.
The dispute stems from Stiens’s 2017 dismissal from his position with the Missouri Department of Agriculture after 17 years of employment. Following a suspension and a probationary period related to alleged policy violations, the department’s human resources director terminated Stiens by letter dated March 8, 2017.
Stiens filed an administrative complaint with the AHC, challenging his termination and the HR director’s authority to remove him. The AHC initially ruled in favor of the Department, and a circuit court later upheld that decision.
On appeal, the appellate court determined that the HR director did not have statutory authority to terminate Stiens and remanded the case for the AHC to determine the effective date of his termination.
After a hearing, the AHC reaffirmed March 8, 2017, as the termination date, concluding that Stiens was not entitled to back pay.
Stiens again sought judicial review, and in December 2022, the Nodaway Circuit Court found the AHC had erred in setting the date. The court ruled that Stiens’s termination did not take effect until April 19, 2017, when the department’s director officially opposed his administrative appeal.
The court ordered the AHC to award Stiens back pay and benefits for the period between March 8 and April 19, 2017, “with interest at the statutory rate.”
When the case returned to the AHC, the commission awarded Stiens $5,983.01 in back pay but denied his request for interest, citing a lack of statutory authority to include it.
The circuit court upheld that determination in August 2024, and Stiens filed a motion for reconsideration, which the court denied, stating that such a motion had “no legal effect” under Missouri law.
The court further rejected Stiens’s arguments regarding estoppel and waiver, finding no evidence that the Department of Agriculture engaged in “affirmative misconduct” or that its failure to appeal the earlier judgment prevented it from opposing his claim for interest.
The court observed that the 2022 circuit court judgment did not itself grant interest but merely stated that interest would apply if authorized by law.
Concluding that the AHC acted within its statutory limits, the appellate panel affirmed the judgment of the circuit court, leaving intact the AHC’s award of $5,983.01 in back pay without interest.
Missouri Court of Appeals, Western District case number: WD87634
