Stone v. Mo. Dep’t of Health & Senior Servs.

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Catherine Stone was employed as a nurse at a nursing facility when she physically restrained a patient in an attempt to force-feed the patient medication. The Department of Health and Senior Services placed Stone on the employee disqualification list for eighteen months after finding that Stone knowingly abused a patient. Stone sought review of the Department's decision, arguing that (1) there was insufficient evidence to support the decision because expert testimony was required to prove that she knowingly abused a patient with dementia and mental disabilities, and (2) the Department deprived her of due process of law by allegedly failing to provide notice of her violations. The circuit court reversed the decision of the Department. The Department appealed, and after opinion by the court of appeals, the Supreme Court granted transfer. The Supreme Court reversed the judgment of the trial court, holding (1) the Department's lay witnesses' testimony was substantial and competent evidence that Stone knowingly abused a patient; (2) the Department provided her with notice of her violations, and therefore, Stone's due process rights were not violated; and (3) the decision of the Department was authorized by law and supported by substantial and competent evidence.