On February 24, 2009, the Missouri Supreme Court in Cynthia Hill v. Ford Motor Co. held that harassment claims under the Missouri Human Rights Act (MHRA) are to be analyzed under the contributing factor test announced in Daugherty v. City of Maryland Heights, continuing the trend of differentiating the MHRA from Title VII. The court also held that individual liability may be imposed not only on supervisors, but on anyone acting in the interest of the employer, even if the individual is not named in the underlying charge of discrimination.