Justia Iowa Supreme Court Opinion Summaries

Grady Billick sought workers’ compensation benefits for a series of work-related injuries. Roberts Dairy, Billick’s current employer, contended that its liability for Billick’s industrial disability should be apportioned because Billick was previously compensated for his losses of earning capacity arising from previous injuries through settlements with previous employers. The Workers’ Compensation Commissioner concluded that Roberts’s liability for permanent partial disability benefits could not be apportioned under the circumstances of this case. The district court reversed, concluding that the Commissioner misapprehended the relevant statutes. The Supreme Court reversed, holding that there was no error in the Commissioner’s interpretation of the relevant statutes. View "Roberts Dairy v. Billick" on Justia Law

Plaintiffs initiated suit in federal district court against Defendant, their former employer, alleging employment discrimination. Plaintiff’s complaint included claims that Defendant had violated Iowa Code 216.6A, Iowa’s equal pay law. Defendants moved for partial summary judgment, arguing that Plaintiffs’ claims under section 216.6A should be dismissed to the extent that they arose before the effective date of that provision. After hearing oral arguments, the district court certified two questions to the Supreme Court to clarify Iowa law with respect to wage discrimination claims. The Supreme Court answered (1) section 216.6A applies on a prospective basis only to conduct occurring after its effective date; and (2) plaintiffs may recover damages for wage discrimination under the preexisting law, Iowa Code 216.6, and recoverable damages for loss of income are based on discriminatory wage payments that occurred within 300 days before the plaintiff filed a complaint with the civil rights commission. View "Dindinger v. AllSteel, Inc." on Justia Law

Kevin Fink filed a petition requesting alternate medical treatment for knee injuries allegedly sustained during the course of his employment with Denison Municipal Utilities (DMU). The workers’ compensation commissioner sent DMU a notice providing that DMU was required to file a first report of injury pursuant to Iowa Code 86.12. When DMU failed to file the first report of injury, the deputy commissioner assessed $1,000 against DMU. The district court reversed the $1,000 assessment, concluding that the deputy commissioner incorrectly interpreted section 86.12 as authorizing the commissioner to demand DMU to file a first report of injury, that the first report of injury was not required by section 86.11, and therefore, the record lacked substantial evidence to support the assessment against DMU. The Supreme Court reversed, holding (1) in this case, DMU was required to file a first report of injury; and (2) the deputy commissioner’s decision that DMU failed to make a sufficient showing of good cause to avoid the $1,000 assessment pursuant to section 86.12 was supported by substantial evidence. View "Denison Mun. Utils. v. Iowa Workers’ Comp. Comm’r" on Justia Law

The Workers’ Compensation Commission found Employee to be totally and permanently disabled under the odd-lot doctrine and denied Employer and its Insurer (collectively, Employer) certain credits for disability payments previously received by Employee from other sources. The district court affirmed the Commission’s finding that Employee was totally and permanently disabled but reversed on the credit issue. The court of appeals reversed, holding (1) substantial evidence did not support the Commission’s award of permanent total benefits, and (2) the Commission was correct in its decision concerning the credits. On further review, the Supreme Court (1) affirmed the district court’s finding that substantial evidence supported the Commission’s findings that Employee was totally and permanently disabled under the odd-lot doctrine; and (2) reversed the district court’s judgment regarding the issues concerning the credit due Employer. View "Gits Mfg. Co. v. Frank" on Justia Law

Dennis Smith was formerly employed by the College of Engineering at Iowa State University (ISU), where he was “subjected to wrongful conduct for an extended period of time in a job he had held for nearly a decade.” Smith filed suit against ISU and the State, alleging, inter alia, that he suffered retaliation for reporting managerial misconduct to ISU’s president. After a jury trial, Smith recovered $500,000 for intentional infliction of emotional distress and $784,027 under a whistleblowing statute. The court of appeals affirmed the intentional infliction of emotional distress award but set aside the statutory whistleblowing award, finding that Smith had failed to prove a causal relationship between his disclosures to the president and any actions of reprisal taken against him. The Supreme Court (1) affirmed the jury’s emotional distress award, holding that Defendants’ conduct toward Smith was outrageous and that the verdict was not excessive; and (2) reduced, but did not set aside, the district court’s award of damages under the whistleblowing statute, where the evidence supported the finding that Smith suffered retaliation for reporting managerial misconduct but where Smith’s loss of his job was not causally linked to his discussion with ISU’s president. View "Smith v. Iowa State Univ. of Sci. & Tech." on Justia Law

Plaintiffs, fourteen African-Americans, brought a class action suit against the State, including thirty-seven different executive branch departments, under the Federal Civil Rights Act and the Iowa Civil Rights Act. In their complaint, Plaintiffs alleged that the State unlawfully discriminates against African Americans in employment. The district court entered judgment in favor of the State. The Supreme Court affirmed, holding that Plaintiffs did not meet their burden of establishing that the underlying documents did not provide sufficient information to allow employment practices to be separated for meaningful statistical analysis, and therefore, Defendant was entitled to summary judgment under the Iowa Civil Rights Act.View "Pippen v. State" on Justia Law

John Goodpaster worked as a customer service manager for Schwan’s Home Service, Inc., the largest home delivery frozen foods company in the nation, at Schwan’s Des Moines location. Goodpaster’s duty was to sell and deliver company products, and a basic requirement of Goodpaster’s job was that he drive a commercial vehicle. When Goodpaster began experiencing medical problems, his sales began to decrease, and he was eventually terminated. Goodpaster sued Schwan’s under the Iowa Civil Rights Act (ICRA) for disability discrimination and retaliation, claiming his employment was terminated because he had multiple sclerosis. The district court granted summary judgment in favor of Schwan’s. The Supreme Court reversed, holding (1) multiple sclerosis is a disability contemplated by the ICRA; and (2) a genuine issue of material fact existed regarding whether Goodpaster was qualified to perform the essential functions of his position. Remanded. View "Goodpaster v. Schwan’s Home Serv., Inc." on Justia Law

AFSCME Iowa Council 61, which represents certain State employees in collective bargaining, entered into negotiations with the State regarding its 2013-2015 collective bargaining agreement. The State proposed deleting certain contract provisions from the existing contract that addressed outsourcing of work performed by public employees. AFCME disputed the State’s classification of this provision as a permissive bargaining subject, arguing that the provision was a procedure for staff reduction and therefore a mandatory subject of bargaining. The Iowa Public Employment Relations Board (“PERB”) concluded that the predominate purpose of the proposal was to designate a process for implementing a staff reduction due to outsourcing, and therefore, the proposal was subject to mandatory bargaining. The district court reversed. The Supreme Court affirmed in part and reversed in part, holding (1) to the extent the primary purpose of the proposal was to preclude the State from reducing staff in response to outsourcing, it was a permissive rather than a mandatory subject of bargaining; but (2) if, on remand, PERB determined that the State was permitted to reduce employment resulting from outsourcing, then the proposal may be found to be a mandatory subject of bargaining. View "AFSCME Iowa Council 61 v. State, Dep’t of Admin. Servs." on Justia Law

After taking self-care leave under the Family and Medical Leave Act (FMLA), Plaintiff was terminated from her employment with the State. A jury found the State terminated Plaintiff in violation of her rights under the FMLA. The district court awarded Plaintiff money damages and ordered the State to reinstate Plaintiff to her former position. The State appealed and successfully requested a stay of Plaintiff’s reinstatement pending the outcome of the appeal. The Supreme Court subsequently held that sovereign immunity precluded Plaintiff’s judgment for money damages against the State. On remand, the district court once again ordered Plaintiff reinstated and awarded lost wages and benefits from the date of the original reinstatement order, concluding that the State had waived its sovereign immunity by seeking a stay of the reinstatement order and promising to pay Plaintiff’s interim wages and benefits if the Court affirmed the original order. The Supreme Court affirmed, holding (1) Plaintiff’s pleadings were sufficient to preserve her right to Ex parte Young remedies, and the parties litigated the reinstatement remedy by consent; and (2) the Eleventh Amendment to the U.S. Constitution does not bar an award of wages and benefits for the period during which a reinstatement order was stayed. View "Lee v. State" on Justia Law

In 2005, James House began working as a commercial truck driver for Mike Brooks, Inc. In 2007, House slipped and fell in any icy parking lot while retrieving cargo and injured his back. House returned to work but experienced regular back pain after doing so. In 2008, House pushed open a heavy door and experienced an increase in pain and a burning sensation in the area of his 2007 back injury. House filed a petition for workers’ compensation benefits. A deputy commissioner found House had sustained a permanent total disability (PTD) and rejected Brooks’ contention that the 2008 incident resulted in an injury distinct from the 2007 injury. The commissioner affirmed the award of PTD benefits, including the finding that House’s injury and resulting PTD were caused by the 2007 incident. The district court affirmed. The court of appeals reversed, concluding that the commissioner’s finding of causation was not supported by substantial evidence. The Supreme Court vacated the court of appeals and affirmed the district court’s decision, holding that substantial evidence supported the causation finding made by the commissioner. View "Mike Brooks, Inc. v. House" on Justia Law