Justia Iowa Supreme Court Opinion SummariesArticles Posted in Labor & Employment Law
Chavez v. MS Technology LLC
The Supreme Court affirmed the decision of the district court affirming the conclusion of the workers' compensation commissioner that Claimant's rotator cuff injury was a scheduled shoulder injury rather than an unscheduled whole body injury under Iowa Code 85.34(2), holding that there was no error.Claimant sustained a work-related injury that was diagnosed as a "full thickness rotator cuff tear that has retracted to the level of the glenoid, severe AC arthrosis, tendonitis and tearing of the biceps tendon." In seeking permanent partial disability benefits, Claimant argued that her injury qualified as an unscheduled injury to the body as a whole, entitling her to industrial disability benefits. The commissioner concluded that Claimant's rotator cuff injury was a scheduled injury to the shoulder, and the district court affirmed. The Supreme Court affirmed, holding that the district court properly determined (1) Claimant's rotator cuff injury was a scheduled shoulder injury under Iowa Code 85.34(2)(n); and (2) substantial evidence supported the commissioner's finding that Claimant failed to prove her biceps tear resulted in a permanent disability to her arm under section 85.34(2)(m). View "Chavez v. MS Technology LLC" on Justia Law
Vroegh v. Iowa Department of Corrections
The Supreme Court affirmed in part and reversed in part the judgment of the district court denying Employer's motion for a new trial and motion for judgment notwithstanding the verdict following a jury trial on Employee's claims of sex and gender identity discrimination and dismissing Employee's claims against a third-party administrator on summary judgment, holding that the court erred in part.Specifically, the Supreme Court (1) reversed the district court's denial of Employer's motion for judgment notwithstanding the verdict and dismissed the jury's verdict as to Employee's sex discrimination claims, holding that the district court erred in submitting the sex discrimination claim to the jury; (2) affirmed the jury's verdicts as to employee's gender identity discrimination claims; (3) affirmed the jury's damages award in favor of Employee in the full amounts that the jury entered; and (4) affirmed the district court's grant of summary judgment in favor of Employer. View "Vroegh v. Iowa Department of Corrections" on Justia Law
Askvig v. Snap-On Logistics Co.
The Supreme Court affirmed the order of the district court granting Employer's motion to dismiss a petition for judicial review as untimely, holding that the district court correctly dismissed Claimant's petition for judicial review.Claimant sustained a work injury and pursued workers' compensation benefits. The workers' compensation benefits ordered Employer to pay temporary total disability benefits related to Claimant's right extremity injury but rejected Claimant's claim that she had also sustained a right shoulder occupational injury. According to Iowa Code 17A.19(3), Claimant had thirty day to file a petition for judicial review. Claimant's attorney failed to file the petition by the deadline. When the attorney realized his oversight, Claimant filed a petition for judicial review. The district court dismissed the petition as untimely. The Supreme Court affirmed, holding that the district court did not err. View "Askvig v. Snap-On Logistics Co." on Justia Law
Godfrey v. State
The Supreme Court reversed the judgment of the district court in favor of Plaintiff on his claims of sexual orientation discrimination and retaliation under the Iowa Civil Rights Act (ICRA), Iowa Code 216.1-.21, holding that Defendants were entitled to judgment as a matter of law with respect to all claims, notwithstanding any errors.After Republican Terry Branstad defeated incumbent Democratic Governor Chet Culver Brandstad requested that thirty executive branch officers appointed by prior Democratic administrations each submit a letter of resignation. After Plaintiff refused to resign the Governor reduced his compensation. Plaintiff then brought this suit, alleging sexual orientation discrimination and retaliation and violations of his constitutional right to be paid a particular salary. A jury rendered a verdict in favor of Plaintiff. The Supreme Court reversed, holding (1) the district court erred in denying Defendants' motions for directed verdict and for judgment notwithstanding the verdict with respect to Plaintiff's claims arising under the ICRA; and (2) Plaintiff's constitutional claim failed as a matter of law. View "Godfrey v. State" on Justia Law
Rumsey v. Woodgrain Millwork, Inc.
The Supreme Court reversed the judgment of the district court concluding that Employer discriminated against Employee by firing him when he sought a reasonable accommodation for a disability, holding that Defendants were entitled to judgment as a matter of law on each of Employee's disability discrimination claims except his claims for failure to accommodate and retaliation based on his request for a sign language interpreter.Employee, who had a preexisting hearing impairment, continued to work while rehabilitating from a workplace injury, and Employer assisted the rehabilitation by providing light-duty work. When a disagreement arose as to whether Employee was entitled to a specific work restriction, Employee was fired. A jury awarded Employee damages after finding that Employer discriminated against him when Employee sought a reasonable accommodation for a disability. The Supreme Court reversed, holding (1) to the extent Plaintiff's disability claims were based on the workplace injury, Plaintiff's failure to identify a job he could perform apart from the temporary light-duty work defeated his claims; and (2) Employer was entitled to a new trial on Employee's disability claims stemming from his request for a sign language interpreter. View "Rumsey v. Woodgrain Millwork, Inc." on Justia Law
Woods v. Charles Gabus Ford, Inc.
The Supreme Court affirmed in part and reversed in part the judgment of the district court dismissing Plaintiff's complaint alleging that Defendant, his employer, did not substantially comply with Iowa Code 730.5(15) when it drug tested him and then terminated him after he tested positive for methamphetamine, holding that equitable relief was appropriate based on the facts of this case.After Plaintiff was randomly selected for a drug test the lab technician rejected Plaintiff's first sample for being insufficient. The second sample tested positive for methamphetamine. Following Plaintiff's termination, Defendant sent Plaintiff a letter informing him of the drug test results and his right to get a confirmatory test. Plaintiff then brought this complaint alleging that the letter did not substantially comply with section 730.5. The district court dismissed the petition. The Supreme Court affirmed in part and reversed in part, holding that Defendant failed to substantially comply with section 730.5(7)(j)(1) when it failed to include the cost of a retest in its notice to Plaintiff. View "Woods v. Charles Gabus Ford, Inc." on Justia Law
Dix v. Casey’s General Stores, Inc.
The Supreme Court affirmed the judgment of the district court concluding that two of Employer's employees were improperly classified as engaged in safety-sensitive positions so that they should never have been drug tested and were entitled to relief and that two other employees were not aggrieved by Employer's actions in attempting to comply with the statutory requirements, holding that there was no error.Employer in this case amended its drug-testing policy to allow for unannounced random drug testing. Plaintiffs, three employees who tested positive and were terminated and a fourth who failed to provide an adequate sample, brought this action under the civil remedies provision of Iowa Code 730.5 arguing that Employer failed to follow statutory requirements involving workplace drug testing. The district court granted relief to two of the four plaintiffs. The Supreme Court affirmed, holding (1) two of the employees should not have been tested under Employer's testing program and were entitled to relief; and (2) the other two employees were not entitled to relief. View "Dix v. Casey's General Stores, Inc." on Justia Law
Iowa Ass’n of Business & Industry v. City of Waterloo
The Supreme Court affirmed in part and reversed in part the judgment of the district court finding that a 2019 Waterloo "ban the box" ordinance was not preempted, holding that the ordinance was preempted to the extent that it purported to regulate a term and condition of employment.In 2017, the legislature adopted a statute, codified at Iowa Code 364.3(12)(a), that prohibits cities from adopting or administering an ordinance providing for any terms or conditions of employment exceeding or conflicting with state or federal law requirements relating to certain employment issues. In 2019, the City of Waterloo enacted the ordinance at issue, which regulated the time when an employer can inquire into a prospective employee's criminal history. The district court concluded that no part of the ordinance was preempted. The Supreme Court reversed in part, holding (1) the ordinance was preempted to the extent it purported to regulate whether an employer can consider an employee's criminal history at all; and (2) the ordinance was not preempted where it only regulated timing because that was not a term or condition of employment. View "Iowa Ass’n of Business & Industry v. City of Waterloo" on Justia Law
Williams v. Bullock
The Supreme Court affirmed the ruling of the district court ruling that Plaintiff's employer had complied with Iowa Code 35C.6 when it terminated the employment of Plaintiff, a military veteran, from his job as a police officer at the University of Iowa's (UI) Department of Public Safety (DPS), holding that the district court did not err.Plaintiff was charged with misconduct after he violated DPS policies. Following arbitration, Plaintiff was terminated and was later reinstated without back pay. Plaintiff filed a petition for writ of certiorari alleging that DPS violated section 35C.6 in his initial termination. The district court ruled that DPS had complied with section 35C.6 as interpreted in Kern v. Saydel Community School District, 637 N.W.2d 157 (Iowa 2001). The Supreme Court affirmed, holding (1) this Court declines to overrule Kern; and (2) the district court correctly determined that the State complied with Iowa Code 35C.6 in terminating Plaintiff. View "Williams v. Bullock" on Justia Law
Andrew v. Hamilton County Public Hospital
The Supreme Court reversed the judgment of the district court denying Hamilton County Public Hospital's motion for summary judgment concerning Plaintiff's defamation claim and Iowa Wage Payment Collection Law (IWPCL) claim, holding that Plaintiff's defamation and statutory wage claims failed.Plaintiff, a general surgeon, was employed by the hospital. After an investigation, Plaintiff's employment through a for-cause provision in his contract was terminated. The hospital subsequently made two reports to the Iowa Board of Medicine and the National Practitioner Data Bank. Plaintiff then brought this action. The hospital moved for summary judgment on the defamation and IWPCL claims, but the district court denied the motion. The Supreme Court reversed on interlocutory appeal, holding (1) Plaintiff's defamation claim failed because the challenged portions of the reports were nonactionable opinions; and (2) Plaintiff's statutory wage claim failed because he did not perform work for which he was not paid. View "Andrew v. Hamilton County Public Hospital" on Justia Law