Justia Iowa Supreme Court Opinion Summaries

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

As a condition of her employment, Employee signed an agreement to arbitrate claims with Employer. Employee later filed a complaint with the Iowa Civil Rights Commission (ICRC), alleging that Employer had discriminated against her because of her pregnancy. The ICRC subsequently filed a statement of charges with the Iowa Department of Inspections and Appeals (DIA). Employer filed a motion to dismiss the ICRC’s charges or, in the alternative, compel arbitration. The DIA denied Employer’s motion on the ground that ICRC was not a party to the arbitration agreement and, consequently, not bound by it. On judicial review, the district court remanded instructions for the ICRC to dismiss the matter pending arbitration by the parties, concluding that the Federal Arbitration Act (FAA) preempted state law. The Supreme Court reversed, holding the FAA did not require arbitration of this proceeding because it was brought by an entity that was not bound to arbitrate under generally applicable principles of contract law, where the ICRC was not a party to the agreement and its interest was not derivative of Employee’s. View "Rent-A-Center, Inc. v. Iowa Civil Rights Comm’n" on Justia Law

Plaintiff, an employee of BNSF Railway Company, was injured due to the railroad’s negligence. Because of his injury, Plaintiff was no longer able to work at his job. Plaintiff, who was almost fifty-nine years old, sued BNSF under the Federal Employers’ Liability Act (FELA) seeking $755,000 in economic damages, claiming that he planned to work until he was sixty-six years old. BNSF, in turn, attempted to introduce evidence that Plaintiff was eligible to retire on full benefits at age sixty and that most railroad employees in Plaintiff’s position retire at age sixty. The district court excluded the railroad’s evidence based on its reading of the federal collateral source rule applicable to FELA cases. A jury subsequently awarded $1.25 million, including pain and suffering, to Plaintiff. The Supreme Court reversed and remanded for a new trial on damages, holding (1) when a railroad employee makes a claim of lost earning capacity based on a hypothetical retirement age, federal law does not bar the introduction of evidence as to when railroad employees in the plaintiff’s position typically retire; and (2) BNSF was improperly precluded from presenting this excluded statistical evidence, and the error was not harmless. View "Giza v. BNSF Ry. Co." on Justia Law

Petitioner was a middle school teacher involved in a physical altercation with a student. The Iowa Board of Educational Examiners issued a statement of charges against Petitioner alleging student abuse. The Board subsequently imposed a ninety-day suspension of Petitioner's teaching license and permanent revocation of his physical education and coaching endorsements. Petitioner filed a petition for judicial review in district court within thirty days of the Board's denial of his application for rehearing but before the Board's final decision on the State's application for rehearing. The district court ultimately affirmed the Board's decision on the merits. The court of appeals reversed, holding that Petitioner's "premature" petition never invoked the district court's jurisdiction. The Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court, holding (1) the proper time to file a petition for judicial review is within thirty days after the agency's final decision on the last application granted for rehearing; and (2) Petitioner initially appealed prematurely before the Board's final decision on the State's rehearing application, but he later perfected his appeal to the district court. View "Christiansen v. Iowa Bd. of Educ. Examiners" on Justia Law

Douglas Moad was driving his truck within the course of his employment with Employer when his truck was struck by an oncoming vehicle. Douglas died from his injuries. Employer maintained workers' compensation services with Dakota Truck Underwriters (DTU), a South Dakota corporation with its principal place of business in South Dakota. Employer also maintained motorist liability coverage with Northland Insurance Company (Northland). Douglas and his wife Sharon maintained insurance coverage with Property and Casualty Insurance Company of Hartford (Hartford). Sharon filed a petition seeking damages from Northland and Hartford for uninsured motorist benefits. DTU filed a notice of subrogation lien, asserting that it was entitled to reimbursement from any proceeds obtained by Sharon as a result of the damages action. Sharon reached a settlement agreement with Northland and Hartford. The district court approved the settlement and granted Sharon's motion to extinguish DTU's lien, concluding that in the event DTU's untimely filing of notice of its lien did not bar its interest, Iowa law applied and barred DTU's recovery. The Supreme Court reversed, holding that the district court utilized the wrong standard in resolving the conflict of laws question. View "Moad v. Dakota Truck Underwriters, Risk Admin. Servs., Inc." on Justia Law

Employee sought unemployment benefits from Iowa Workforce Development after his discharge from employment by Employer. An ALJ concluded Employee was not entitled to benefits, and the Employment Appeal Board (EAB) affirmed. Employee petitioned for judicial review, naming Employer in the caption as a "defendant." The caption made no mention of the EAB, but the body of the petition made it plain that the appeal was being taken from the final action of the EAB. The petition was timely served on the EAB. The district court dismissed the petition, concluding that Employee's failure to list the EAB as a respondent in the caption was fatal. The Supreme Court reversed and remanded, holding that the district court erred in dismissing the petition where Employee substantially complied with the relevant statute by identifying the EAB as the agency who entered the final agency action from which Employee sought to appeal. Thus, the petition was sufficient to vest subject matter jurisdiction with the district court. View "Cooksey v. Cargill Meat Solutions Corp." on Justia Law

Employee was injured while working for Employer and was awarded permanent partial disability benefits. Employee subsequently petitioned to review-reopen his workers' compensation claim, seeking additional workers' compensation benefits, seeking reimbursement for additional postarbitration medical expenses, requesting a determination of the amount of workers' compensation benefits still owed by Employer and its insurer, and asking the court to decide whether the workers' compensation commissioner needed to enter an additional order compelling payment to enforce an arbitration award for the unpaid benefits. The district court (1) rejected Employee's petition for review as untimely; (2) affirmed denial of reimbursement for some of Employee's medical expenses; and (3) did not provide the requested calculation but ruled that a compel-payment order was unnecessary because Employee could seek a judgment to enforce the award. The Supreme Court (1) reversed as to the statute of limitations for a petition for review-reopening; and (2) affirmed as to the judgment regarding which medical expenses were causally connected to the work-related injury. Remanded to the district court for it to remand the matter to the commissioner with directions to decide the issues regarding the amount still owed to Employee by Employer and its insurer under the arbitration award. View "Coffey v. Mid Seven Transp. Co." on Justia Law

Plaintiff filed a wrongful discharge suit against the State. The State moved to dismiss the action for failure to exhaust administrative remedies as required by the Iowa Tort Claims Act (Act). The district court granted the motion, holding that the claim was a tort subject to the Act. After an unsuccessful appeal, Plaintiff filed her lawsuit in district court a second time. The district court held that Plaintiff failed to comply with the statute of limitations and dismissed the second lawsuit. The Supreme Court reversed, holding that Plaintiff properly complied with the savings clause of the statute of limitations under the Act once the district court determined the Act provided the exclusive remedy for her claim. Remanded. View "Rivera v. Woodword Res. Ctr." on Justia Law

Employee, who was injured while working for Employer, sought enforcement of an arbitration award he received from the workers' compensation commissioner against Employer and Employer's insurer. Employee requested the district court to determine the amount Employer and its insurer (collectively, Appellees) owed him under the arbitration award in light of Employee's claim that Appellees failed to pay all of the medical benefits, mileage reimbursements, and interest due under the arbitration decision. Appellees claimed a credit against any amount they owed Employee due to his third-party settlements. After a hearing, the district court declined to answer the issues raised by the parties and declined to determine the amount still owed to Employee under the arbitration decision, concluding that addressing the issues in Employee's petition required the district court to exceed its authority. The Supreme Court reversed and remanded to the district court for the court to remand the matter to the commissioner with directions to decide the issues Employee raised in his petition for judgment. View "Coffey v. Mid Seven Transp. Co." on Justia Law