Justia Iowa Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the district court affirming the decision of the workers’ compensation commissioner declining to award benefits to a fast-food employee who suffered serious head injuries when he fell backwards directly to a tile floor after having a seizure while handling a customer order, holding that there is no blanket rule rendering certain categories of workplace idiopathic falls noncompensable.The commissioner reasoned that idiopathic falls from a standing or walking position to a level floor do not arise out of employment under the workers’ compensation law. The district court affirmed. The Supreme Court reversed, holding (1) whether injuries suffered in an idiopathic fall directly to the floor at a workplace arises out of employment is a factual matter, not a legal one, and the factual question to be determined is whether a condition employment increased the risk of injury; and (2) the commissioner in this case incorrectly treated a factual issue as a legal matter. View "Bluml v. Dee Jay's Inc." on Justia Law

Plaintiff could not prove the City discriminated against him because of his multiple sclerosis (MS) when the City was unaware he had MS.Plaintiff applied for a full-time job as a firefighter with the City of Marion. The City denied Plaintiff’s application after a physician reported that Plaintiff was not medically qualified for the position, but the physician did not inform the City that MS was the reason Plaintiff was found unfit for firefighting. Plaintiff later sued the City and the physician’s employer under the Iowa Civil Rights Act (ICRA) alleging disability discrimination. The district court granted summary judgment for all defendants. The Supreme Court affirmed, holding (1) without any requested accommodation by Plaintiff, the City had no duty to second-guess the physician that Plaintiff was medically unqualified for the position; and (2) the physician was not liable for aiding and abetting the discrimination without proof that the City intentionally discriminated against Plaintiff. View "Deeds v. City of Marion, Iowa" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court granting summary judgment in favor of Defendants on Plaintiff’s claims challenging his termination.Plaintiff, a former chief administrative law judge of the Unemployment Insurance Appeals Bureau in Iowa Workforce Development (IWD), alleged retaliation under the whistleblower protection provisions of Iowa Code 70A.28 and that Defendants continued to retaliate against him when he sought other positions in state government. Plaintiff further alleged wrongful termination in violation of public policy based upon the same conduct. The district court granted summary judgment for Defendants, concluding that Plaintiff could not bring his claims because he failed to exhaust his administrative remedies available to merit employees. The Supreme Court reversed in part, holding (1) Plaintiff’s ability to bring a direct claim under section 71A.28 is not precluded by the availability of an administrative remedy under Iowa Code 8A.415; and (2) the district court correctly granted summary judgment on Plaintiff’s wrongful termination claim. View "Walsh v. Wahlert" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court granting summary judgment in favor of Defendants on Plaintiff’s claims challenging his termination.Plaintiff, a former chief administrative law judge of the Unemployment Insurance Appeals Bureau in Iowa Workforce Development (IWD), alleged retaliation under the whistleblower protection provisions of Iowa Code 70A.28 and that Defendants continued to retaliate against him when he sought other positions in state government. Plaintiff further alleged wrongful termination in violation of public policy based upon the same conduct. The district court granted summary judgment for Defendants, concluding that Plaintiff could not bring his claims because he failed to exhaust his administrative remedies available to merit employees. The Supreme Court reversed in part, holding (1) Plaintiff’s ability to bring a direct claim under section 71A.28 is not precluded by the availability of an administrative remedy under Iowa Code 8A.415; and (2) the district court correctly granted summary judgment on Plaintiff’s wrongful termination claim. View "Walsh v. Wahlert" on Justia Law

The equitable tolling doctrines of the discovery rule and equitable estoppel are available with respect to the 300-day filing limitation in the Iowa Civil Rights Act (ICRA).Plaintiff, an applicant for the position of Deputy Workers’ Compensation Commissioner at Iowa Workforce Development (IWD), brought a failure-to-hire claim against the IWD. The district court dismissed the claim, concluding that Plaintiff could not escape the 300-day filing requirement in the ICRA through application of the discovery rule or equitable estoppel. The Supreme Court affirmed, holding (1) the discovery rule and equitable estoppel apply to the 300-day filing limitation in the ICRA; but (2) Plaintiff was not entitled to toll the filing limitation through application of either the discovery rule or equitable estoppel. View "Mormann v. Iowa Workforce Development" on Justia Law

The equitable tolling doctrines of the discovery rule and equitable estoppel are available with respect to the 300-day filing limitation in the Iowa Civil Rights Act (ICRA).Plaintiff, an applicant for the position of Deputy Workers’ Compensation Commissioner at Iowa Workforce Development (IWD), brought a failure-to-hire claim against the IWD. The district court dismissed the claim, concluding that Plaintiff could not escape the 300-day filing requirement in the ICRA through application of the discovery rule or equitable estoppel. The Supreme Court affirmed, holding (1) the discovery rule and equitable estoppel apply to the 300-day filing limitation in the ICRA; but (2) Plaintiff was not entitled to toll the filing limitation through application of either the discovery rule or equitable estoppel. View "Mormann v. Iowa Workforce Development" on Justia Law

Retaliatory discharge claims are not categorically reserved for at-will employees.A state administrative law judge (ALJ) brought suit alleging wrongful termination in violation of public policy after she was terminated for giving unfavorable testimony about the director of her division to the Iowa Senate Government Oversight Committee. The ALJ’s employment was covered by a collective bargaining agreement (CBA). The State filed a motion to dismiss, asserting that the common law claim of wrongful discharge is reserved for at-will employees. The district court agreed and dismissed the case. The court of appeals reversed, concluding that the ALJ’s status as a CBA-covered employee did not preclude her wrongful-discharge claim. The Supreme Court affirmed, holding that the common law tort of retaliatory discharge against public policy is generally available to contract employees. View "Ackerman v. State" on Justia Law

Retaliatory discharge claims are not categorically reserved for at-will employees.A state administrative law judge (ALJ) brought suit alleging wrongful termination in violation of public policy after she was terminated for giving unfavorable testimony about the director of her division to the Iowa Senate Government Oversight Committee. The ALJ’s employment was covered by a collective bargaining agreement (CBA). The State filed a motion to dismiss, asserting that the common law claim of wrongful discharge is reserved for at-will employees. The district court agreed and dismissed the case. The court of appeals reversed, concluding that the ALJ’s status as a CBA-covered employee did not preclude her wrongful-discharge claim. The Supreme Court affirmed, holding that the common law tort of retaliatory discharge against public policy is generally available to contract employees. View "Ackerman v. State" on Justia Law

The Supreme Court affirmed the decision of the district court affirmed the decision of the workers’ compensation commissioner that Claimant was not entitled to healing period benefits under Iowa Code 85.34(1).Claimant filed a petition seeking workers’ compensation benefits after developing bilateral carpal tunnel injuries allegedly arising out of and in the course of her employment with Employer. Employer admitted liability and authorized Claimant to undergo medical care with its chosen medical providers. Claimant, however, sought medical treatment from an unauthorized physician. The physician performed two surgeries on Claimant, and Employer refused to pay healing period benefits for the time Claimant was recovering from the unauthorized surgeries. The commissioner concluded that Claimant was not entitled to healing period benefits because Employer provided a valid authorization defense. The district court affirmed. The Supreme Court affirmed, concluding that where Claimant received unauthorized medical care she was not entitled to healing benefits. View "Brewer-Strong v. HNI Corp." on Justia Law

The Supreme Court reversed the decision of the district court denying Employer’s motion for summary judgment on Employee’s lawsuit filed under the Iowa Civil Rights Act (ICRA) alleging that Employer discriminated against him based on his age, sex, and national origin.Matthew Jahnke, an employee of Deere & Co., worked as a factor manager at Harbin Works in Harbin, China under a contract with a Deere Chinese subsidiary. As discipline for Jahnke engaging in sexual relationships with two Chinese employees, Jahnke was ultimately removed as the factor manager, repatriated back to the United States, and assigned to a position of lesser authority and lower pay in Waterloo, Iowa. Jahnke filed suit under the ICRA. In its motion for summary judgment, Deere claimed that the ICRA did not apply extraterritorially and that Jahnke based his claims on allegations of discriminatory acts that occurred outside of Iowa. The district court denied the motion. The Supreme Court reversed, holding (1) the ICRA does not apply extraterritorially; and (2) because Jahnke failed to show that either he or Deere was located within Iowa for purposes of the alleged discriminatory act, Jahnke had no claim under the ICRA. View "Jahnke v. Deere & Co." on Justia Law