Justia Iowa Supreme Court Opinion SummariesArticles Posted in Labor & Employment Law
Valdez v. West Des Moines Community Schools
The Supreme Court affirmed the judgment of the district court concluding that Desira Johnson, a teacher at the West Des Moines Community Schools (the District), was not subject to individual liability under the Iowa Civil Rights Act (ICRA) on Plaintiff's claim of constructive discharge, holding that there was no error.Plaintiff, a teacher's associate who worked with special education students in the District, sued the District and Johnson, alleging that Johnson engaged in racial discrimination, leading to Plaintiff's constructive discharge in violation of the ICRA. The jury returned a defense verdict in favor of the District. The Supreme Court affirmed, holding (1) the district did not err in overruling Plaintiff's Batson challenge to Defendants' peremptory strike of the only Black potential juror; (2) the district court did not err in granting Johnson's motion for directed verdict for correction of errors at law; and (3) Plaintiff was not entitled to relief on her allegations of error in the district court's evidentiary rulings. View "Valdez v. West Des Moines Community Schools" on Justia Law
Carver-Kimm v. Reynolds
The Supreme Court affirmed in part and reversed in part the judgment of the district court in this wrongful discharge action, holding that the district court did not err in denying the motion to dismiss Plaintiff's claims against the State but erred in denying the motion to dismiss the claims against the Governor and the Governor's communications director.In her complaint, Plaintiff alleged that she was forced out of her employment with the Iowa Department of Public Health because she refused to stifle certain public records requests to the Department. In their motion to dismiss, Defendants argued, among other claims, that qualified immunity barred Plaintiff's claims. The district court denied the motion. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) correctly denied Plaintiff's motion to dismiss the claims against the State; but (2) erred in denying Plaintiff's motion to dismiss her claims against the Governor and his communications director for wrongful discharge under Iowa Code 70A.28 and wrongful discharge in violation of public policy. View "Carver-Kimm v. Reynolds" on Justia Law
McCoy v. Thomas L. Cardella & Associates
The Supreme Court reversed the judgment of the district court denying Thomas L. Cardella & Associates' (Cardella) motion for judgment notwithstanding the verdict in this case alleging common law negligent supervision or retention, holding that the claim was barred by the Iowa Workers' Compensation Act (IWCA), Iowa Code ch. 85.Plaintiff sued Cardella two years after she quit her employment there. Because she missed the deadline for bringing a hostile work environment claim under the Iowa Civil Rights Act (ICRA), Iowa Code ch. 216, Plaintiff sued for common law negligent supervision or retention and presented her claim to the jury seeking emotional distress damages related to her mental health as a negligent supervision claim premised on Cardella failing to protect her from assault and battery. After a trial, the jury awarded Plaintiff $400,000 in emotional distress damages. The Supreme Court reversed, holding that, as presented to the jury, Plaintiff's claim was barred by IWCA. View "McCoy v. Thomas L. Cardella & Associates" on Justia Law
Hedlund v. State
The Supreme Court reversed the decision of the district court granting Larry Hedlund's motion seeking retrospective application of the amendments to Iowa's whistleblower-protection law, Iowa Code section 70A.28, holding that section 70A.28(5)(a) did not apply retrospectively to Hedlund's claims.Hedlund brought a lawsuit against the State asserting a claim for wrongful discharge under section 70A.28. While the lawsuit was pending, the legislature amended the statute to allow aggrieved employees to pursue damages beyond those allowed by the prior version of the statute. Thereafter, Defendant filed a motion asserting that the new amendments applied retroactively to him. The district court granted the motion. The Supreme Court reversed, holding that because the legislature made to express provision for retrospective application the amendments to chapter 70A.8 did not apply in this case. View "Hedlund v. State" on Justia Law
Konchar v. Pins
The Supreme Court affirmed the decision of the district court granting summary judgment to Defendants as to some of Plaintiff's claims and the judgment entered on the defense verdicts on Plaintiff's remaining defamation claims, holding that Plaintiff had not shown grounds for reversal.Plaintiff, the former principal at St. Joseph's Catholic School, brought this action against Father Josephs Pins, St. Joseph's Church, and the Diocese of Des Moines after her employment was terminated, alleging fraud and defamation by all defendants and breach of contract against Father Pins. The district court granted summary judgment in favor of Defendants as to Plaintiff's fraud, breach of contract, and defamation claims, and then a jury returned defense verdicts on the remaining defamation claims. The Supreme Court affirmed, holding that Plaintiff was not entitled to reversal on his allegations of error. View "Konchar v. Pins" on Justia Law
Green v. North Central Iowa Regional Solid Waste Authority
The Supreme Court affirmed the rulings of the district court and court of appeals that the workers' compensation commissioner erred in granting Employer's motion for summary judgment and dismissing Employee's review-reopening petition, holding that Employee was permitted to pursue a claim for a permanent injury in a review-reopening proceeding despite an earlier adjudication that her injury was not permanent.Employee was injured during the course and work of her employment. Employee filed a petition seeking workers' compensation for a permanent disability, but the deputy commissioner refused to order additional benefits beyond those that Employer had already paid. Employee filed a petition for review-reopening with the workers' compensation commission. The commission determined that Employee's claim for permanent disability benefits was barred by principles of res judicata. The district court reversed, and the court of appeals affirmed. The Supreme Court affirmed, holding that the agency erred in dismissing Employer's review-reopening petition. View "Green v. North Central Iowa Regional Solid Waste Authority" on Justia Law
Blasdell v. Linnhaven, Inc.
The Supreme Court affirmed the judgment of the district court reversing the decision of the workers' compensation commissioner denying the claim filed by the husband of a deceased employee for burial expenses and death benefits as the surviving spouse, holding that the district court did not err.Approximately two and a half years into her marriage Wife left her marital home with Husband, accepted a job in a different city, and moved in with a family friend. Husband and Wife never divorced. Wife was subsequently permanently and totally disabled as a result of a work injury and was awarded workers' compensation benefits. Four years later, Wife died from an overdose. Husband filed a claim for burial expenses and death benefits as the surviving spouse. Employer/Insurer denied the claim. The commissioner upheld the denial, concluding that Husband had willfully deserted Wife without any fault by her and thus was not entitled to benefits under Iowa Code 85.42(1)(a). The district court reversed. The Supreme Court affirmed, holding that there was not substantial evidence to support the commissioner's finding that Husband deserted Wife without fault by her under section 85.42(1)(a). View "Blasdell v. Linnhaven, Inc." on Justia Law
Dornath v. Employment Appeal Bd.
The Supreme Court reversed the decisions of the district court and employment appeal board affirming the decision of the department of workforce development denying Appellant's claim for unemployment benefits, holding that Appellant's claims on appeal were unavailing.Appellant, an apprentice electrician, attended a week-long training as part of his apprenticeship curriculum, and his employer didn't pay him for that week. Appellant filed a claim for unemployment benefits under Iowa Code 96.4(3), arguing that he met the statute's criteria that he be able to work, available for work, and actively seeking work. The department of workforce development denied the claim, and the employment appeal board and district court affirmed. The Supreme Court affirmed, holding that the board's decision that Appellant had not established his eligibility for benefits was not an erroneous interpretation of the law, unsupported by substantial evidence in the record, or an abuse of the board's discretion. View "Dornath v. Employment Appeal Bd." on Justia Law
Feeback v. Swift Pork Co.
The Supreme Court affirmed the judgment of the district court dismissing Plaintiff's claims against Defendants for wrongful termination, workplace harassment, and age discrimination, holding that the district court properly granted summary judgment on all claims.Plaintiff, an at-will employee, was promptly fired after he texted his plant manager "FUCK You!" and "Believe who and what you want" following the manager's criticism of his job performance. In response to Plaintiff's complaint, Defendants moved for summary judgment on the grounds that Plaintiff was lawfully fired for insubordination. The district court granted summary judgment in favor of Defendants. The Supreme Court modified the McDonnell-Douglas burden-shifting framework for summary judgment on discrimination claims under the Iowa Civil Rights Act to align with the causation standard at trial and adopted and applied the good-faith "honest believe rule" to affirm Defendant's decision to terminate Plaintiff's employment for insubordination. View "Feeback v. Swift Pork Co." on Justia Law
Copeland v. State
The Supreme Court held that Iowa Code 35C.8, an exception to the veterans preference statute that applies to veterans who "hold a strictly confidential relation to the appointing officer" does not apply unless the veteran had a direct reporting relationship with the appointing officer.At issue before the Supreme Court was whether to read the exception to apply to veterans who have no direct relationship with "the appointing officer" or to read it more narrowly, as it did in Ervin v. Triplett, to not apply to veterans who worked in jobs that require "skill, judgment, trust, and confidence." 18 N.W.2d 599, 602 (Iowa 1945). The Supreme Court held that Ervin's narrow reading was the better approach, thus preventing the exception from "swallowing" the veterans preference by largely confining it to jobs that require "no discretion or responsibility." The Court thus vacated the decision of the court of appeals and reversed the district court's denial of a petition for writ of certiorari, holding that the district court erred in finding that the exception applied to Petitioner, who did not report to the "appointing officer." View "Copeland v. State" on Justia Law