Justia Iowa Supreme Court Opinion Summaries

The Supreme Court reversed the decisions of the district court and employment appeal board affirming the decision of the department of workforce development denying Appellant's claim for unemployment benefits, holding that Appellant's claims on appeal were unavailing.Appellant, an apprentice electrician, attended a week-long training as part of his apprenticeship curriculum, and his employer didn't pay him for that week. Appellant filed a claim for unemployment benefits under Iowa Code 96.4(3), arguing that he met the statute's criteria that he be able to work, available for work, and actively seeking work. The department of workforce development denied the claim, and the employment appeal board and district court affirmed. The Supreme Court affirmed, holding that the board's decision that Appellant had not established his eligibility for benefits was not an erroneous interpretation of the law, unsupported by substantial evidence in the record, or an abuse of the board's discretion. View "Dornath v. Employment Appeal Bd." on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Plaintiff's claims against Defendants for wrongful termination, workplace harassment, and age discrimination, holding that the district court properly granted summary judgment on all claims.Plaintiff, an at-will employee, was promptly fired after he texted his plant manager "FUCK You!" and "Believe who and what you want" following the manager's criticism of his job performance. In response to Plaintiff's complaint, Defendants moved for summary judgment on the grounds that Plaintiff was lawfully fired for insubordination. The district court granted summary judgment in favor of Defendants. The Supreme Court modified the McDonnell-Douglas burden-shifting framework for summary judgment on discrimination claims under the Iowa Civil Rights Act to align with the causation standard at trial and adopted and applied the good-faith "honest believe rule" to affirm Defendant's decision to terminate Plaintiff's employment for insubordination. View "Feeback v. Swift Pork Co." on Justia Law

The Supreme Court held that Iowa Code 35C.8, an exception to the veterans preference statute that applies to veterans who "hold[] a strictly confidential relation to the appointing officer" does not apply unless the veteran had a direct reporting relationship with the appointing officer.At issue before the Supreme Court was whether to read the exception to apply to veterans who have no direct relationship with "the appointing officer" or to read it more narrowly, as it did in Ervin v. Triplett, to not apply to veterans who worked in jobs that require "skill, judgment, trust, and confidence." 18 N.W.2d 599, 602 (Iowa 1945). The Supreme Court held that Ervin's narrow reading was the better approach, thus preventing the exception from "swallowing" the veterans preference by largely confining it to jobs that require "no discretion or responsibility." The Court thus vacated the decision of the court of appeals and reversed the district court's denial of a petition for writ of certiorari, holding that the district court erred in finding that the exception applied to Petitioner, who did not report to the "appointing officer." View "Copeland v. State" on Justia Law

The Supreme Court held that the Iowa Public Employee Relations Board (PERB) and the district court misinterpreted Iowa Code 20.32 by extending broader bargaining rights to nontransit employees in the same bargaining unit as public transit employees, holding that the plain meaning of the statute protects only transit employees, not nontransit employees in the same bargaining unit.The City of Ames sought guidance as to whether section 20.32 requires broader bargaining rights for nontransit employees in the same bargaining unit. PERB concluded that broader bargaining rights must be extended under the statute to nontransit employees in a bargaining unit consisting of at least thirty percent transit employees, and the district court affirmed. The Supreme Court reversed, holding that the City was not required to provide broader bargaining rights to nontransit employees, regardless of the percentage of transit employees in the bargaining unit. View "City of Ames v. Iowa Public Employment Relations Bd." on Justia Law

The Supreme Court reversed the judgment of the district court affirming the decision of the workers' compensation commissioner denying Petitioner's petition for benefits for trauma-induced mental injuries she suffered on the job while working as emergency dispatcher, holding that because Petitioner established that her PTSD resulted from a manifest happening of a sudden traumatic nature from an unexpected cause or unusual strain, Petitioner was entitled workers' compensation benefits.Petitioner, a sixteen-year veteran of the county emergency dispatch system, sought benefits for the PTSD she suffered after taking a 911 call from a woman screaming over and over at a high pitch, "Help me, my baby is dead." The workers' compensation commissioner and district court denied benefits, concluding that the mother's call wasn't an "unexpected cause or unusual strain." The Supreme Court reversed, holding that Petitioner was entitled to benefits because she established that her PTSD resulted from a manifest happening of a sudden traumatic nature from an unexpected cause or unusual strain. View "Tripp v. Scott Emergency Communication Center" on Justia Law

The Supreme Court affirmed the decision of the district court affirming the conclusion of the workers' compensation commissioner that Claimant's rotator cuff injury was a scheduled shoulder injury rather than an unscheduled whole body injury under Iowa Code 85.34(2), holding that there was no error.Claimant sustained a work-related injury that was diagnosed as a "full thickness rotator cuff tear that has retracted to the level of the glenoid, severe AC arthrosis, tendonitis and tearing of the biceps tendon." In seeking permanent partial disability benefits, Claimant argued that her injury qualified as an unscheduled injury to the body as a whole, entitling her to industrial disability benefits. The commissioner concluded that Claimant's rotator cuff injury was a scheduled injury to the shoulder, and the district court affirmed. The Supreme Court affirmed, holding that the district court properly determined (1) Claimant's rotator cuff injury was a scheduled shoulder injury under Iowa Code 85.34(2)(n); and (2) substantial evidence supported the commissioner's finding that Claimant failed to prove her biceps tear resulted in a permanent disability to her arm under section 85.34(2)(m). View "Chavez v. MS Technology LLC" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court denying Employer's motion for a new trial and motion for judgment notwithstanding the verdict following a jury trial on Employee's claims of sex and gender identity discrimination and dismissing Employee's claims against a third-party administrator on summary judgment, holding that the court erred in part.Specifically, the Supreme Court (1) reversed the district court's denial of Employer's motion for judgment notwithstanding the verdict and dismissed the jury's verdict as to Employee's sex discrimination claims, holding that the district court erred in submitting the sex discrimination claim to the jury; (2) affirmed the jury's verdicts as to employee's gender identity discrimination claims; (3) affirmed the jury's damages award in favor of Employee in the full amounts that the jury entered; and (4) affirmed the district court's grant of summary judgment in favor of Employer. View "Vroegh v. Iowa Department of Corrections" on Justia Law

The Supreme Court affirmed the order of the district court granting Employer's motion to dismiss a petition for judicial review as untimely, holding that the district court correctly dismissed Claimant's petition for judicial review.Claimant sustained a work injury and pursued workers' compensation benefits. The workers' compensation benefits ordered Employer to pay temporary total disability benefits related to Claimant's right extremity injury but rejected Claimant's claim that she had also sustained a right shoulder occupational injury. According to Iowa Code 17A.19(3), Claimant had thirty day to file a petition for judicial review. Claimant's attorney failed to file the petition by the deadline. When the attorney realized his oversight, Claimant filed a petition for judicial review. The district court dismissed the petition as untimely. The Supreme Court affirmed, holding that the district court did not err. View "Askvig v. Snap-On Logistics Co." on Justia Law

The Supreme Court reversed the judgment of the district court in favor of Plaintiff on his claims of sexual orientation discrimination and retaliation under the Iowa Civil Rights Act (ICRA), Iowa Code 216.1-.21, holding that Defendants were entitled to judgment as a matter of law with respect to all claims, notwithstanding any errors.After Republican Terry Branstad defeated incumbent Democratic Governor Chet Culver Brandstad requested that thirty executive branch officers appointed by prior Democratic administrations each submit a letter of resignation. After Plaintiff refused to resign the Governor reduced his compensation. Plaintiff then brought this suit, alleging sexual orientation discrimination and retaliation and violations of his constitutional right to be paid a particular salary. A jury rendered a verdict in favor of Plaintiff. The Supreme Court reversed, holding (1) the district court erred in denying Defendants' motions for directed verdict and for judgment notwithstanding the verdict with respect to Plaintiff's claims arising under the ICRA; and (2) Plaintiff's constitutional claim failed as a matter of law. View "Godfrey v. State" on Justia Law

The Supreme Court reversed the judgment of the district court concluding that Employer discriminated against Employee by firing him when he sought a reasonable accommodation for a disability, holding that Defendants were entitled to judgment as a matter of law on each of Employee's disability discrimination claims except his claims for failure to accommodate and retaliation based on his request for a sign language interpreter.Employee, who had a preexisting hearing impairment, continued to work while rehabilitating from a workplace injury, and Employer assisted the rehabilitation by providing light-duty work. When a disagreement arose as to whether Employee was entitled to a specific work restriction, Employee was fired. A jury awarded Employee damages after finding that Employer discriminated against him when Employee sought a reasonable accommodation for a disability. The Supreme Court reversed, holding (1) to the extent Plaintiff's disability claims were based on the workplace injury, Plaintiff's failure to identify a job he could perform apart from the temporary light-duty work defeated his claims; and (2) Employer was entitled to a new trial on Employee's disability claims stemming from his request for a sign language interpreter. View "Rumsey v. Woodgrain Millwork, Inc." on Justia Law