Justia Iowa Supreme Court Opinion Summaries

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

Employee injured her right ankle when she slipped and fell during the course of her employment. Employer later terminated Employee's employment. Employee filed a claim with the workers' compensation commission seeking benefits as a result of her alleged injuries. The commissioner ruled in favor of Pease, concluding that she suffered an injury to the body as a whole and that her work injury was a substantial contributory factor in her state of depression. The commissioner awarded Pease permanent total disability, accrued benefits, and reimbursement for medical expenses. The district court affirmed the commissioner's findings of fact with respect to the causation of Employee's mental and physical injuries and held that substantial evidence supported the commissioner's findings regarding disability. The court of appeals reversed the award, finding substantial evidence did not support the commissioner's findings on causation. The Supreme Court vacated the court of appeals and affirmed the district court, holding that the commissioner's findings of fact were supported by substantial evidence. View "Cedar Rapids Cmty. Sch. Dist. v. Pease" on Justia Law

Employee filed a personal injury lawsuit against a company under common ownership with Employer and ultimately settled the claim. About nine months after the settlement, Employer terminated Employee's employment. Employee filed suit against Employer, asserting an intentional tort claim for wrongful termination in violation of public policy and claiming that Employer terminated his employment because he brought the previous personal injury claim. The district court granted Employer motion to dismiss for failure to make a claim. The court of appeals reversed. On review, the Supreme Court vacated the court of appeals and affirmed the district court, holding that Iowa Code 668, the state's comparative fault statute, did not contain a clearly defined and well-recognized public policy of the state limiting an employer's discretion to discharge an at-will employee. View "Berry v. Liberty Holdings, Inc." on Justia Law