Justia Iowa Supreme Court Opinion Summaries

The plaintiffs, peace officers employed by the Iowa Department of Corrections, alleged that they were disciplined following administrative investigations and subsequently requested copies of witness statements and investigation reports related to their cases. They claimed that the Department refused to provide these documents as required by Iowa Code chapter 80F. The officers filed a lawsuit seeking money damages and injunctive relief, asserting that the Department violated their rights under chapter 80F.The Iowa District Court for Polk County granted summary judgment in favor of the Iowa Department of Corrections, dismissing the officers' lawsuit. The district court concluded that chapter 80F did not grant the officers a right to bring a cause of action against their employing agency.The Iowa Supreme Court reviewed the case and affirmed the district court's decision. The court held that Iowa Code § 80F.1(13) does not provide a private right of action for officers against their employing agency. The court reasoned that the term "person" in § 80F.1(13) does not include government agencies, and the statute does not explicitly exempt the officers' claims from the exclusive remedies provided under the Iowa Administrative Procedure Act (chapter 17A). Therefore, the officers must follow the procedures outlined in chapter 17A to challenge the Department's actions. The court concluded that the officers' claims did not have a direct path to the courthouse through § 80F.1(13) and affirmed the summary judgment in favor of the Department. View "Chandler v. Iowa Department of Corrections" on Justia Law

A financial advisor, employed by Principal Securities, Inc., was terminated for failing to obtain a second client consent when rebalancing accounts using a new trading system. The advisor argued that the termination report filed by Principal with the Financial Industry Regulatory Authority (FINRA) was misleading and initiated arbitration to seek changes to the report. The arbitrator ruled in favor of the advisor, recommending changes to the termination report to reflect that the advisor's failure was due to a lack of training and that the advisor was encouraged not to resign during the investigation.The Iowa District Court for Polk County vacated the arbitration award, finding it unsupported by substantial evidence. The advisor appealed, and the case was transferred to the Iowa Court of Appeals. A divided panel of the Court of Appeals affirmed the district court's decision, with the majority agreeing that the information provided by Principal was not defamatory or misleading. The dissenting judge believed that substantial evidence supported the arbitration award.The Iowa Supreme Court reviewed the case and applied a highly deferential standard of review. The court concluded that substantial evidence supported the arbitrator's determination that the termination report was misleading and that the recommended changes were justified. The court vacated the decision of the Court of Appeals, reversed the district court's judgment, and remanded the case with instructions to confirm the arbitration award. View "Principal Securities, Inc. v. Gelbman" on Justia Law

Regena Strable, a marketing director at Altoona Nursing and Rehabilitation Center, injured her left ankle at work, leading to permanent partial disability. This injury caused further physical injuries to her hip and lower back, as well as mental injuries such as post-traumatic stress disorder and anxiety. Strable had previously suffered carpal tunnel injuries to both wrists a decade earlier. After settling with her employer for the ankle injury and the sequela injuries, Strable sought benefits from the Second Injury Fund of Iowa based on her prior carpal tunnel injuries.The deputy commissioner denied Strable’s request for benefits from the Fund, concluding that Iowa Code section 85.64 imposes liability on the Fund only when the second injury is limited to a scheduled injury. The Iowa Workers’ Compensation Commissioner disagreed and granted benefits. On judicial review, the Iowa District Court for Polk County reversed the Commissioner’s decision, agreeing with the deputy commissioner that awarding benefits from the Fund would result in double recovery for Strable.The Iowa Supreme Court reviewed the case and reversed the district court’s order. The court held that the Fund is liable under Iowa Code section 85.64 if the first and second qualifying injuries caused a compensable injury to an enumerated member, regardless of whether the injuries caused other non-enumerated or unscheduled injuries. The court found that the Commissioner erred in calculating the Fund’s liability by not including the employer’s liability for the sequela injuries. The case was remanded to the Commissioner for a determination of the amount and timing of the Fund’s liability, consistent with the court’s opinion. View "Second Injury Fund of Iowa v. Strable" on Justia Law

An employee, Ashley Koester, worked as a mobile crisis counselor for Eyerly-Ball Community Health Services. She believed she was entitled to overtime compensation for her on-call hours and filled out timesheets accordingly, which were approved by her supervisor. Later, her employer objected to the overtime payments and terminated her employment. Koester sued her employer under Iowa Code chapter 91A and for wrongful discharge in violation of public policy, claiming she was terminated for asserting her right to overtime pay.The Iowa District Court for Polk County dismissed Koester's claims, ruling that she did not have a claim under chapter 91A because she had been paid in full, including for the overtime hours she claimed. The court also found her statutory claim time-barred. Koester appealed, and the Iowa Court of Appeals reversed the dismissal of her public policy claim but affirmed the dismissal of her statutory claim.The Iowa Supreme Court reviewed the case and concluded that Koester did not state a claim for relief under chapter 91A or the common law tort of wrongful discharge in violation of public policy. The court held that chapter 91A is a wage collection law, not a generalized fair practices law, and since Koester did not have a claim for unpaid wages, she was not entitled to relief. The court also determined that Koester's public policy claim failed because she was not engaged in protected activity under the statute, as she did not file a complaint or claim unpaid wages before her termination. The Iowa Supreme Court vacated the decision of the Court of Appeals and affirmed the District Court's judgment dismissing Koester's claims. View "Koester v. Eyerly-Ball Community Mental Health Services" on Justia Law

Todd Halbur was terminated from his position as comptroller of the Iowa Alcoholic Beverages Division (ABD). Halbur claimed he was fired in retaliation for reporting to his supervisor, Stephen Larson, that ABD was violating Iowa law by exceeding the 50% markup on liquor sales and for refusing to engage in illegal acts related to a service contract with Beverage Merchandising, Inc. (BMI). Halbur filed a lawsuit against Larson, asserting a statutory claim for wrongful discharge under Iowa Code section 70A.28 and a common law claim for wrongful discharge in violation of public policy. The district court submitted the statutory claim to a jury but dismissed the common law claim, ruling that the statutory claim was the exclusive remedy. The jury awarded Halbur $1 million, which was reduced due to a statutory cap on damages.The Iowa District Court for Polk County dismissed Halbur’s common law wrongful discharge claim, reasoning that the statutory claim under section 70A.28 provided a comprehensive remedy. The court also dismissed the statutory claims against the State of Iowa and ABD, allowing the claim to proceed only against Larson in his official capacity. Larson’s motion for summary judgment was initially granted in part but later reconsidered, allowing the case to proceed to trial. The jury found in favor of Halbur, awarding him damages.The Iowa Supreme Court reviewed the case. Larson argued that Halbur’s internal complaints did not constitute protected disclosures under section 70A.28. However, the court found that Larson failed to preserve this issue for appeal by not raising it during trial through a motion for directed verdict or judgment notwithstanding the verdict. On cross-appeal, Halbur argued that his common law claim should not have been dismissed. The court affirmed the district court’s decision, holding that the statutory remedy under section 70A.28 was exclusive and comprehensive, precluding the need for a common law claim. The court affirmed the judgment of the district court. View "Halbur v. Larson" on Justia Law

The case involves Dee Delaney, an employee who suffered two separate injuries to her legs in 1986 and 2019. The latter injury, which occurred during her employment with Nordstrom, Inc., required knee surgery and resulted in lymphedema in Delaney's lower right leg and foot. Delaney filed a claim for workers’ compensation benefits against Nordstrom and the Second Injury Fund of Iowa (the Fund). She reached a settlement with Nordstrom and proceeded to arbitration against the Fund. The workers’ compensation commissioner found that Delaney’s lymphedema was a sequela of her work injury and that lymphedema is per se an injury to the body as a whole and not an injury to a scheduled member. The commissioner concluded that because Delaney suffered a sequela injury to the body as a whole, she was not entitled to Fund benefits under Iowa Code section 85.64 (2019).The Iowa District Court for Polk County affirmed the workers’ compensation commissioner’s denial of Second Injury Fund benefits to Delaney. The court agreed with the commissioner's interpretation of section 85.64, which led to the conclusion that Delaney was not entitled to Fund benefits because her lymphedema was considered an injury to the body as a whole, not an injury to a scheduled member.The Supreme Court of Iowa reversed the district court's judgment and vacated the decision of the court of appeals. The court held that the commissioner erred in its interpretation and application of section 85.64. The court found that whether an injury results in the “loss of use” to a scheduled member or extends to the body as a whole is a fact-based inquiry that must be determined on a case-by-case basis. The court also held that an injury resulting in the loss of use of a scheduled member was a qualifying injury under section 85.64, even if the injury caused a sequela injury to the body as a whole. The case was remanded to the district court with instructions to remand this matter to the workers’ compensation commissioner for further proceedings consistent with this opinion. View "Delaney v. Second Injury Fund of Iowa" on Justia Law

The case involves Tracy White, an employee of the Iowa Department of Human Services (DHS), who filed a lawsuit against the State of Iowa and DHS under the Iowa Civil Rights Act (ICRA) alleging a hostile work environment. White's complaints about her supervisor led to his termination, but she remained employed at the agency. The jury awarded her $260,000 for past emotional distress and $530,000 for future emotional distress. The State appealed, arguing that the evidence was insufficient to prove White's hostile work environment claim, that the district court erred by admitting certain evidence and incorrectly instructing the jury, and that the future emotional distress damages were excessive.The district court had denied the State's pretrial motion to exclude certain evidence, referred to as "me too" evidence, as unduly prejudicial. This evidence consisted of reports of alleged discrimination experienced by other employees, which White, as a supervisor, had received and relied on to support her own hostile work environment claim. The State argued that such evidence, of which White was unaware, could not prove that she personally experienced a hostile work environment.The Supreme Court of Iowa agreed with the State, concluding that the harassment White personally experienced was not objectively severe or pervasive enough to alter the terms or conditions of her employment. The court held that the district court erred by denying the State's motion for judgment notwithstanding the verdict (JNOV). The court reversed the judgment for White and remanded the case for entry of an order granting the State's motion for JNOV. View "White v. State" on Justia Law

In the Supreme Court of Iowa, a case involved Bridgestone Americas, Inc., and Old Republic Insurance Company, appellants, against Charles Anderson, appellee. Anderson, an employee of Bridgestone, reported a right shoulder injury and a right arm injury after decades of manual labor. He pursued a workers’ compensation action, which was awarded by the deputy workers’ compensation commissioner and affirmed by the workers’ compensation commissioner. The employer sought judicial review, and the district court affirmed the commissioner’s decision.The employer appealed, posing three questions: whether the injuries were compensable, whether they should be compensated as unscheduled injuries under Iowa Code section 85.34(2)(v), and whether the compensation was calculated correctly. The court concluded that the injuries were compensable but should be classified as scheduled injuries under Iowa Code section 85.34(2), paragraphs (m) and (n), not unscheduled injuries.The court affirmed the district court’s decision in part, reversed in part, and remanded the case for determination of compensation for the employee's scheduled injuries, meaning compensation should be based on the extent to which a body part's function has been impaired, not the employee's loss of earning capacity. View "Bridgestone Americas, Inc. v. Anderson" on Justia Law

In this case, decided by the Supreme Court of Iowa, Justin Loew, an employee of Menard, Inc., appealed the district court's decision that denied his claim for workers' compensation benefits. Loew had previously received benefits for a 20% functional impairment to his lower back caused by a work-related injury in 2015, which had been calculated using the industrial method and resulted in a 30% reduction in his earning capacity. In 2018, Loew suffered a second work-related injury to his lumbar spine which increased his functional impairment to 28%. Under the 2017 changes to the workers' compensation law, Loew's compensation for this injury was to be based solely on his functional impairment, since he returned to work at the same or greater wages. However, the workers' compensation commissioner denied Loew any additional benefits for his second injury, reasoning that Menard was entitled to offset the prior payment based on reduced earning capacity against the new claim for functional impairment.The Supreme Court of Iowa disagreed with the commissioner's reasoning and reversed the district court's judgment. The court held that it was incorrect to offset compensation based on loss of earning capacity (from the first injury) against compensation based on functional impairment (from the second injury), as these are incommensurables. Further, the court found that the commissioner erred in interpreting Iowa Code section 85.34(7) to preclude compensation for Loew's new permanent partial disability, as this statute only limits an employer's liability for preexisting disabilities that have already been compensated. Loew was seeking compensation for a new permanent partial disability, not a preexisting one, hence Menard was liable for this new disability. The court remanded the case back to the commissioner for further proceedings consistent with its opinion. View "Loew v. Menard, Inc." on Justia Law

Marshall Sandlin, a laborer at Mid American Construction LLC, suffered an injury to his left foot during work. After an initial medical examination conducted by a physician chosen by Mid American's insurance carrier, Grinnell Mutual, Sandlin underwent another independent medical examination (IME) by a physician of his choosing. Sandlin sought reimbursement for the full cost of this second examination, as he believed the first examination's evaluation was too low.The Supreme Court of Iowa had to decide whether an amendment to Iowa Code section 85.39(2) in 2017 limited an employee's reimbursement for an IME to only the cost of the impairment rating or included the full cost of the examination. The court held that the employee is eligible for reimbursement of the reasonable cost of the full examination to determine the impairment rating, not merely the cost of the impairment rating itself. The court interpreted the term "examination" as used in the statute to include review of medical records, physical examination, testing, and written report.However, the court found that the commissioner's analysis of the physician's fee as reasonable was incomplete. While the commissioner considered the physician's written opinion about the reasonableness of his fee, the commissioner failed to analyze the typical fee charged for such an examination in the local area where the examination was conducted, as required by the 2017 amendment to the statute. Consequently, the court remanded the case for further fact-finding on the issue of the reasonableness of the fee based on the typical fee charged in the local area.Thus, the Supreme Court of Iowa affirmed in part and vacated in part the decision of the Court of Appeals and affirmed in part, reversed in part, and remanded the judgment of the District Court. View "Mid American Construction LLC v. Sandlin" on Justia Law