Justia Iowa Supreme Court Opinion Summaries

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

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