Justia Iowa Supreme Court Opinion Summaries

Plaintiff worked for over ten years for Dentist. When Dentist's wife found out that her husband and Plaintiff often texted each other, she demanded that he terminate Plaintiff's employment. Dentist subsequently terminated Plaintiff's employment. Plaintiff brought this action against Dentist, alleging that Dentist discriminated against her on the basis of sex. The district court granted summary judgment for Dentist, finding that Plaintiff was not fired because of her gender but because she was a threat to Dentist's marriage. The Supreme Court affirmed, holding that Dentist's conduct here did not amount to unlawful sex discrimination in violation of the Iowa Civil Rights Act. View "Nelson v. Knight" on Justia Law

At issue in this case was whether a trial court's entry of a default judgment under Iowa R. Civ. P. 1.971(3) is justified when a party fails to appear personally for trial, but the party's attorney is present and able to proceed in the client's absence. The court of appeals affirmed the district court's entry of default judgment due to Plaintiff's failure to appear personally at the time of his scheduled trial. The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the district court, holding that because Rule 1.971(3) does not require a party to appear personally for trial, it was an abuse of discretion to enter a default judgment against Plaintiff when his counsel was present and able to proceed to trial on his behalf. View "Jack v. P & A Farms, Ltd." on Justia Law

In this case the Supreme Court was asked to determine whether Iowa's workers' compensation statute allows a claimant to recover healing period benefits - after he had reached maximum medical improvement and returned to substantially similar work following a work-related injury - for a period of approximately thirteen weeks of postsurgical convalescence during which he was unable to work. The workers' compensation commission awarded such benefits, and the district court affirmed. The court of appeals reversed on the ground that Iowa Code 85.34(1) did not authorize the benefits under the circumstances of this case. The Supreme Court vacated in part the decision of the court of appeals and affirmed the district court's judgment affirming the award, holding that section 85.34(1) did authorize an award of healing period benefits in this case. View "Waldinger Corp. v. Mettler" on Justia Law

At issue in this employment case was whether the State was immune from claims under the self-care provision of the Family and Medical Leave Act (FMLA) in state court. The district court denied the State's posttrial motions for a judgment notwithstanding the verdict or a new trial asserting Eleventh Amendment sovereign immunity after a jury awarded damages to a state employee based on a claim for violating the FMLA. The court of appeals affirmed. The Supreme Court vacated the decision of the court of appeals and reversed the judgment of the trial court, holding (1) the cloak of immunity granted to the State precludes state employees from suing the State for monetary relief when denied self-care leave under the FMLA; (2) nevertheless, states are bound to follow the self-care provisions of the FMLA, and state employees who are wrongfully denied self-care leave are still permitted to seek injunctive relief against the responsible state official; and (3) the U.S. Department of Labor may bring actions for damages or an injunction on behalf of an employee against a state for violating the self-care provisions. Remanded. View "Lee v. State" on Justia Law

Employee sought workers compensation benefits after receiving two injuries at her place of employment. While working for Employer, Employee received a salary increase of $1000. Although Employee received a salary increase of $1000 per month for more than a year, Employer claimed the increase was supposed to have been $1000 per year. The deputy commissioner calculated a weekly compensation rate based on the $1000 per month raise Employer actually paid Employee. The district court reversed and instead used the $1000 per year figure Employer claimed was accurate. The court of appeals reversed and determined that the $1000 per month raise should be included in the calculation of Employee's compensation rate. The Supreme Court vacated the court of appeals and remanded the case for a factual determination as to Employer's claim that it accidentally overpaid Employee $916 per month. View "Burton v. Hilltop Care Ctr." on Justia Law

The Employment Appeal Board (Board) denied Willie Hall's application for unemployment insurance benefits. Hall filed a petition for judicial review. The district court affirmed the decision of the Board and assessed costs against Hall. The court of appeals affirmed. The Supreme Court reversed the portion of the judgment as it related to court costs, holding (1) pursuant to Iowa Code 96.15(2), any individual claiming benefits shall not be charged fees of any kind, including court costs, in a proceeding under the statute by a court or an officer of the court; and (2) therefore, the district court erred by requiring that Hall pay court costs. View "Hall v. Employment Appeal Bd." on Justia Law

Employee injured his shoulder while working for Employer. Employer offered Employee light-duty work in Des Moines, which was 387 miles from Employee's residence. Employee declined Employer's offer to perform light-duty work, and as a result, Employer suspended Employee's workers' compensation benefits. Employee filed a workers' compensation claim. The workers' compensation commissioner concluded (1) Employer improperly suspended temporary disability benefits where Employer failed to offer Employee suitable work because the job was located a great distance from Employee's residence; and (2) Employee experienced a sixty percent industrial disability. The district court reversed in part, concluding that Employer offered Employee suitable work and thus, Employee forfeited his right to benefits during his period of refusal. The Supreme Court reversed in part, holding (1) the commissioner did not err in finding Employer failed to offer Employee suitable work; and (2) the commissioner's findings with respect to the extent of Employee's industrial disability were supported by substantial evidence. View "Neal v. Annett Holdings, Inc." on Justia Law

Employee filed a petition with the state workers' compensation commissioner, alleging that he suffered an injury to his shoulder while working for Employer and that his injury caused a permanent disability. The workers' compensation commissioner concluded that Employee failed to prove his claimed permanent disability was causally related to his work injury. The district court and court of appeals affirmed. The Supreme Court affirmed, holding (1) because an award for partial permanent disability for an unscheduled injury under Iowa Code 85.34(2)(u) is determined by industrial disability, rather than by functional impairment, the commissioner used the correct standard to determine the causal relation between the work injury and the alleged disability; and (2) furthermore, substantial evidence supported the commissioner's findings. View "Westling v. Hormel Foods Corp." on Justia Law

Employer placed a security camera in his workplace to monitor Employee. Employer later installed the camera in the bathroom. Employee and her co-worker discovered the camera and brought suit against Employer for invasion of privacy. Specifically, the employees alleged that Employer's actions fell under the intrusion upon seclusion alternative of the invasion-of-privacy tort. The district court granted Employers' motion for summary judgment, finding insufficient evidence supporting the element of intrusion. The court of appeals reversed. The Supreme Court affirmed the court of appeals and reversed the district court order granting summary judgment in favor of Employer based on the reasoning in Koeppel v. Speirs. Remanded. View "Miller v. Speirs" on Justia Law

Employer secretly installed surveillance equipment in a workplace bathroom. Employee filed a claim for damages against Employer for invasion of privacy and sexual harassment. The district court granted summary judgment for Employer on both claims, holding, inter alia, that although Employer intended to view Employee in the bathroom, the tort of invasion of privacy required proof the equipment had worked and Employer had viewed the plaintiffs. The court of appeals reversed, finding the evidence of intrusion was sufficient to survive summary judgment. The Supreme Court granted further review on the issue involving invasion of privacy and affirmed, holding that the district court erred in granting Employer's motion for summary judgment where an electronic invasion occurs under the intrusion on solitude or seclusion component of the tort of invasion of privacy when the plaintiff establishes by a preponderance of evidence that the electronic device or equipment used by a defendant could have invaded privacy in some way. View "Koeppel v. Speirs" on Justia Law