June 10, 2025
Written by Natalie Hoernschemeyer & Grant Wiens
On June 10, 2025, the Supreme Court of Missouri issued a 5-2 decision affirming a judgment in favor of the Blue Springs R-IV School District in a case brought by a transgender student under the Missouri Human Rights Act (MHRA). The ruling clarifies that the MHRA’s public accommodation protections in connection with restroom and locker room usage apply solely to discrimination based on biological sex and do not extend to claims based on gender identity.
The plaintiff, identified as R.M.A., is a transgender student who transitioned from female to male in childhood while enrolled in the Blue Springs R-IV School District. R.M.A. legally changed his name in 2010 and obtained an amended Missouri birth certificate in 2014, listing his sex as male in accordance with Missouri law.
During his eighth and ninth grade years, R.M.A. sought access to the boys’ restrooms and locker rooms at school. The district denied these requests. R.M.A. brought a lawsuit under the MHRA, alleging sex discrimination in public accommodations in violation of state law. The case proceeded to a jury trial in 2021, where the jury found in favor of R.M.A. and awarded over $4 million in damages, finding that R.M.A. had been discriminated against on the basis of his sex.
Following the verdict, the school district moved for judgment notwithstanding the verdict. The trial court judge granted the motion and set aside the jury’s verdict, concluding that R.M.A. failed to make a submissible case of discrimination based on male sex as defined by the MHRA. R.M.A appealed the trial court’s decision.
Supreme Court Opinion
On appeal, the Missouri Supreme Court affirmed the trial court’s judgment, holding that the term “sex” as used in the MHRA’s public accommodation statute refers exclusively to biological sex. The Court relied on the plain and ordinary meaning of the word “sex,” with the term consistently defined in longstanding dictionary sources as referring to biological characteristics, including reproductive anatomy and genetic composition.
The Court found that R.M.A.’s case failed to establish that he was discriminated against on the basis of his “male sex” as required by the MHRA. The only evidence presented at trial, the Court reasoned, was that the school district denied access to the boys’ facilities because R.M.A. had female genitalia. As such, the decision to exclude R.M.A. was based on his biological characteristics consistent with female sex, not male sex as he had pleaded.
In reaching its conclusion, the Court emphasized that the Missouri General Assembly has, on multiple occasions, declined to amend the MHRA to include gender identity or sexual orientation as protected categories in the context of public accommodations. The Court noted that proposed legislative changes introduced between 2019 and 2024 were considered but never enacted. According to the Court, this legislative history confirmed that the General Assembly did not intend for the MHRA’s existing protections to extend beyond biological sex.
Because the plaintiff failed to establish that his male sex was a contributing factor in the denial of access to the facilities, the Court held that judgment in favor of the school district was appropriate as a matter of law.
Implications for Schools
This decision confirms that, under current Missouri law, public school districts may lawfully maintain restrooms, locker rooms, and other facilities separated by biological sex without violating the Missouri Human Rights Act’s (MHRA) public accommodation provisions. The decision of the Missouri Supreme Court did not address other state or federal laws, with the jury trial focused on the singular issue of the MHRA and biological sex.
We’re Here to Help
For assistance reviewing your school’s compliance obligations under this ruling and related state or federal laws, please contact the Education Law team at Mickes O’Toole.
