The Supreme Court affirmed in part and reversed in part the judgment of the district court granting summary judgment in favor of Defendants on Plaintiff’s claims challenging his termination. Plaintiff, a former chief administrative law judge of the Unemployment Insurance Appeals Bureau in Iowa Workforce Development (IWD), alleged retaliation under the whistleblower protection provisions of Iowa Code 70A.28 and that Defendants continued to retaliate against him when he sought other positions in state government. Plaintiff further alleged wrongful termination in violation of public policy based upon the same conduct. The district court granted summary judgment for Defendants, concluding that Plaintiff could not bring his claims because he failed to exhaust his administrative remedies available to merit employees. The Supreme Court reversed in part, holding (1) Plaintiff’s ability to bring a direct claim under section 71A.28 is not precluded by the availability of an administrative remedy under Iowa Code 8A.415; and (2) the district court correctly granted summary judgment on Plaintiff’s wrongful termination claim. View "Walsh v. Wahlert" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court granting summary judgment in favor of Defendants on Plaintiff’s claims challenging his termination. Plaintiff, a former chief administrative law judge of the Unemployment Insurance Appeals Bureau in Iowa Workforce Development (IWD), alleged retaliation under the whistleblower protection provisions of Iowa Code 70A.28 and that Defendants continued to retaliate against him when he sought other positions in state government. Plaintiff further alleged wrongful termination in violation of public policy based upon the same conduct. The district court granted summary judgment for Defendants, concluding that Plaintiff could not bring his claims because he failed to exhaust his administrative remedies available to merit employees. The Supreme Court reversed in part, holding (1) Plaintiff’s ability to bring a direct claim under section 71A.28 is not precluded by the availability of an administrative remedy under Iowa Code 8A.415; and (2) the district court correctly granted summary judgment on Plaintiff’s wrongful termination claim. View "Walsh v. Wahlert" on Justia Law

The equitable tolling doctrines of the discovery rule and equitable estoppel are available with respect to the 300-day filing limitation in the Iowa Civil Rights Act (ICRA). Plaintiff, an applicant for the position of Deputy Workers’ Compensation Commissioner at Iowa Workforce Development (IWD), brought a failure-to-hire claim against the IWD. The district court dismissed the claim, concluding that Plaintiff could not escape the 300-day filing requirement in the ICRA through application of the discovery rule or equitable estoppel. The Supreme Court affirmed, holding (1) the discovery rule and equitable estoppel apply to the 300-day filing limitation in the ICRA; but (2) Plaintiff was not entitled to toll the filing limitation through application of either the discovery rule or equitable estoppel. View "Mormann v. Iowa Workforce Development" on Justia Law

The equitable tolling doctrines of the discovery rule and equitable estoppel are available with respect to the 300-day filing limitation in the Iowa Civil Rights Act (ICRA). Plaintiff, an applicant for the position of Deputy Workers’ Compensation Commissioner at Iowa Workforce Development (IWD), brought a failure-to-hire claim against the IWD. The district court dismissed the claim, concluding that Plaintiff could not escape the 300-day filing requirement in the ICRA through application of the discovery rule or equitable estoppel. The Supreme Court affirmed, holding (1) the discovery rule and equitable estoppel apply to the 300-day filing limitation in the ICRA; but (2) Plaintiff was not entitled to toll the filing limitation through application of either the discovery rule or equitable estoppel. View "Mormann v. Iowa Workforce Development" on Justia Law

Retaliatory discharge claims are not categorically reserved for at-will employees. A state administrative law judge (ALJ) brought suit alleging wrongful termination in violation of public policy after she was terminated for giving unfavorable testimony about the director of her division to the Iowa Senate Government Oversight Committee. The ALJ’s employment was covered by a collective bargaining agreement (CBA). The State filed a motion to dismiss, asserting that the common law claim of wrongful discharge is reserved for at-will employees. The district court agreed and dismissed the case. The court of appeals reversed, concluding that the ALJ’s status as a CBA-covered employee did not preclude her wrongful-discharge claim. The Supreme Court affirmed, holding that the common law tort of retaliatory discharge against public policy is generally available to contract employees. View "Ackerman v. State" on Justia Law

Retaliatory discharge claims are not categorically reserved for at-will employees. A state administrative law judge (ALJ) brought suit alleging wrongful termination in violation of public policy after she was terminated for giving unfavorable testimony about the director of her division to the Iowa Senate Government Oversight Committee. The ALJ’s employment was covered by a collective bargaining agreement (CBA). The State filed a motion to dismiss, asserting that the common law claim of wrongful discharge is reserved for at-will employees. The district court agreed and dismissed the case. The court of appeals reversed, concluding that the ALJ’s status as a CBA-covered employee did not preclude her wrongful-discharge claim. The Supreme Court affirmed, holding that the common law tort of retaliatory discharge against public policy is generally available to contract employees. View "Ackerman v. State" on Justia Law

The Supreme Court affirmed the decision of the court of appeals finding substantial evidence that the juvenile in this case committed a sex offense by force and that the sex offender registry requirements imposed upon the juvenile by law did not violate the prohibition against cruel and unusual punishment under either the state or federal Constitutions. The juvenile court found the juvenile committed a sex offense by force and required him to register as a sex offender under Iowa Code 692A.103(4), the mandatory sex offender registry statute. The court of appeals affirmed. The Supreme Court affirmed, holding that automatic, mandatory registration for certain juvenile sex offenders is punishment but that such registration does not amount to cruel and unusual punishment. View "In re T.H." on Justia Law

In this medical malpractice action, the Supreme Court affirmed in part and reversed and remanded in part the judgment of the district court removing Plaintiffs’ informed consent claims from this case and entering judgment for Defendants on Plaintiffs’ specific negligence claim. Plaintiffs, a patient and his family, brought this lawsuit against Defendants, a physician and the physician’s employer. The district court granted summary judgment in favor of Defendants on the informed consent claim based on the physician’s failure to disclose his lack of training and experience in performing the procedure and, during trial, refused to allow the informed consent claim based on the physician’s failure to disclose the risk of the surgery considering the patient’s bad heart. The jury then returned a verdict for Defendants on the specific negligence claim. The court of appeals affirmed. The Supreme Court affirmed the judgment on the specific negligence claim but remanded the case to allow Plaintiffs to proceed on their two informed consent claims, holding that the district court erred in removing the two informed consent claims from the case. View "Andersen v. Khanna" on Justia Law

The district court correctly granted summary judgment in favor Humboldt County on Plaintiff’s claim that the county was liable for the injuries she received when her vehicle went off the county road and into a ditch then struck a concrete embankment in the ditch based on the public-duty doctrine. The embankment in this case had been constructed by a private landowner and was on the private landowner’s land, but the county had a right-of-way easement where part of the embankment was located. In her complaint, Plaintiff alleged that the county should have caused the removal of the concrete embankment from the ditch. The Supreme Court affirmed the district court’s grant of summary judgment, holding that the public-duty doctrine is “alive and well in Iowa” and applies to the facts of this case. View "Johnson v. Humboldt County" on Justia Law

The Supreme Court affirmed the decision of the district court affirmed the decision of the workers’ compensation commissioner that Claimant was not entitled to healing period benefits under Iowa Code 85.34(1). Claimant filed a petition seeking workers’ compensation benefits after developing bilateral carpal tunnel injuries allegedly arising out of and in the course of her employment with Employer. Employer admitted liability and authorized Claimant to undergo medical care with its chosen medical providers. Claimant, however, sought medical treatment from an unauthorized physician. The physician performed two surgeries on Claimant, and Employer refused to pay healing period benefits for the time Claimant was recovering from the unauthorized surgeries. The commissioner concluded that Claimant was not entitled to healing period benefits because Employer provided a valid authorization defense. The district court affirmed. The Supreme Court affirmed, concluding that where Claimant received unauthorized medical care she was not entitled to healing benefits. View "Brewer-Strong v. HNI Corp." on Justia Law