Justia Iowa Supreme Court Opinion Summaries

Dennis Smith, a former employee of Iowa State University (ISU), sued ISU and the State of Iowa (collectively, ISU) after his position at the university was eliminated. Smith ultimately recovered $150,000 on his statutory whistleblower claim - reduced from an initial award of $784,027 - and his other claims were dismissed. The district court awarded Smith $368,607 in attorney fees, which amounted to almost all of Smith’s attorney fees incurred in this litigation and other satellite proceedings. The district court awarded the attorneys fees pursuant to Iowa’s whistleblower statute. ISU appealed, arguing that the attorney-fee award should be reduced for work not performed on the whistleblower claim and to account for an overall lack of success on that claim. The Supreme Court reversed that aspect of the district court’s judgment awarding attorney fees to Smith, holding that, given the time Smith’s counsel devoted to unrelated matters for which attorney fees were not authorized and Smith’s limited success on the statutory whistleblower claim, the district court’s attorney fee ruling was an abuse of discretion. Remanded. View "Smith v. Iowa State Univ. of Science & Tech." on Justia Law

In this appeal, the issue this case presented for the Iowa Supreme Court's review was whether an employer’s matching contributions to an employee’s 401k plan should be considered part of weekly earnings for purposes of calculating workers’ compensation weekly benefits. The Court had to also decide whether the district court erred in affirming the workers’ compensation commissioner’s decision on the amount of healing period benefits owed, the extent of permanent disability, and the penalty to be awarded. After review of the specific facts of this case, the Court concluded that an employer’s matching contributions to an employee’s 401k plan were not weekly earnings for purposes of calculating workers’ compensation weekly benefits. The Court also concluded the district court did not err in affirming the decision of the commissioner with respect to the extent of permanent disability. However, the district court erred in affirming the date when healing period benefits commenced, the date when the healing period benefits ended, and the date when permanent partial disability (PPD) benefits commenced. The case was remanded to the district court: (1) to affirm the commissioner’s findings as to the weekly benefit rate and the extent of permanent partial disability; and (2) for a redetermination of the date when healing period benefits commenced, of the date when healing period benefits ended and PPD benefits commenced, and for a recalculation of penalty and interest benefits. View "Evenson v. Winnebago Insudtries, Inc." on Justia Law

Sondra Irving was employed as a medical assistant at the University of Iowa Hospitals and Clinics (UIHC). She was arrested on November 28, 2013, and incarcerated through December 24, but the charges were ultimately dismissed. Irving was scheduled to resume work on December 3. At Irving’s request, her mother called UIHC every work day between December 2 and December 11 to report that Irving would be absent from work. On December 11, an employee at UIHC told Irving’s mother that she did not need to call anymore because Irving had been placed on a leave of absence. Irving’s supervisors at UIHC visited her on December 5 and told her they were doing everything they could to make sure she did not lose her job. Irving’s supervisors continued to visit on visiting days, and they told her that she had been placed on a leave of absence. After she was released, Irving attempted to return to work and was told that she was no longer employed. Irving attempted to reapply for her job and was rejected. Irving applied for unemployment insurance benefits on January 16, 2014, under the Iowa Employment Security Law. Iowa Workforce Development denied her application in a letter stating, “Our records indicate you voluntarily quit work on 12/20/13, because you were arrested and confined in jail. Your quitting was not caused by your employer.” Irving appealed the decision. The district court affirmed. Irving then sought certiorari review. The Supreme Court found that the EAB record did not support a finding of misconduct, and that there was no substantial support to show that Irving's absence from the workplace due to her incarceration was a voluntary quit. Accordingly, the Iowa Supreme Court reversed the EAB's decision and remanded for further proceedings. View "Irving v. Employment Appeal Board" on Justia Law

Employee injured her back during the course of her employment. Employer paid for the cost of care Employee received to treat her injury through September 2009. Employee later brought a workers’ compensation claim seeking workers’ compensation benefits and medical expenses she incurred for additional back treatment between May 2010 and April 2011. The Workers’ Compensation Commissioner concluded that the treatment Employee received between May 2010 and April 2011 was not causally related to her workplace injury but nonetheless awarded Employee medical expenses because Employer failed to notify Employee it was no longer authorizing treatment as required by Iowa Code 85.27(4). The district court reversed in part, concluding that the agency misinterpreted section 85.27(4) and that Employer was not liable for the expenses Employee incurred after September 2009. The court of appeals reversed the portion of the district court judgment reversing the agency’s determination that Employer was liable to Employee for the expenses she incurred from May 2010 through April 2011, concluding that the district court erroneously interpreted section 85.27(4). The Supreme Court affirmed in part and vacated in part the decision of the court of appeals, holding that the Commissioner erroneously interpreted Iowa Code 85.27(4). Remanded. View "Ramirez-Trujillo v. Quality Egg, LLC" on Justia Law

Plaintiff, a former agent of the Iowa Division of Criminal Investigation brought this action alleging wrongful discharge in violation of public policy. The Supreme Court dismissed the common-law wrongful discharge claim. Plaintiff filed a motion to amend findings and conclusions under Iowa R. Civ. P. 1.904(2), which the district court denied. Plaintiff appealed. Plaintiff’s application for leave to appeal was filed more than thirty days after the district court’s order but within thirty days of the court’s denial of Plaintiff’s Rule 1.904(2) motion. The Supreme Court dismissed the appeal, holding that Plaintiff’s appeal was untimely. View "Hedlund v. State" on Justia Law

Tina Lee filed suit against the State, alleging a violation of her rights under the self-care provision of the Family Medical Leave Act (FMLA). In October 2007, the district court entered judgment in favor of Lee and awarded her money damages and attorney fees and costs. In March 2008, the district court ordered the State to pay Lee attorney fees and costs she incurred between October 2007 and February 2008. The Supreme Court reversed. On remand, the district court ordered the State to reinstate Lee and pay her lost wages and benefits from the date of the October 2007 judgment. The district court then ordered the State to pay Lee the attorney fees and costs she was entitled to in its October 2007 and March 2008 orders and to cover the attorney fees and costs Lee incurred between February 2008 and June 2014. The Supreme Court reversed, holding (1) sovereign immunity bars awards of attorney fees and costs incurred in seeking retroactive monetary relief in actions brought against state officials under Ex parte Young to remedy violations of the self-care provision of the FMLA; but (2) state sovereign immunity does not bar awards of attorney fees and costs incurred in seeking prospective relief in such actions. View "Lee v. State" on Justia Law

Plaintiff, who was employed as an engineer and paramedic for the City of Clinton fire department, requested light-duty assignments when she became pregnant. The fire chief denied Plaintiff’s request, determining that she was not entitled to light duty under the city administrative policy because she did not have a disabling injury that occurred on the job. When Plaintiff’s pregnancy had advanced, she took a leave of absence by using accrued vacation and sick leave time. Once she exhausted the vacation and sick leave, her leave of absence was unpaid. After Plaintiff gave birth, she brought a lawsuit against the City of Clinton and three of its employees, alleging pregnancy discrimination under Iowa Code 216.6(2) and violations of her equal protection and due process rights under the Iowa Constitution. The district court granted summary judgment in favor of Defendants. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) the Court’s test for the evaluation of pregnancy discrimination claims is hereby adapted in this opinion; and (2) the material facts of this case do not support equal protection and due process claims under the Iowa Constitution. Remanded for consideration of the statutory civil rights claim under the new standard. View "McQuistion v. City of Clinton" on Justia Law

Employee strained his back while working for Employer. Two years later, Employer notified Employee that it would no longer pay for his medical care, believing that the two-year statute of limitations for workers’ compensation benefits had expired. Employee sought benefits from the Iowa Workers’ Compensation Commission. The deputy commissioner ruled that the two-year statute of limitations in Iowa Code 85.26 barred Employee’s claim and that, even though Employee filed a workers’ compensation proceeding within thirty days after receiving the notice from Employer, the discovery rule did not apply in this case. The district court reversed. The Supreme Court affirmed, holding that the discovery rule applied under the circumstances presented in this case. View "Baker v. Bridgestone/Firestone" on Justia Law

The Workers’ Compensation Core Group of the Iowa Association for Justice filed a petition for declaratory order with the Workers’ Compensation Commissioner seeking a determination whether Iowa Code 85.25(2) mandates that employers or insurance carriers defending workers’ compensation claims must immediately provide copies of surveillance videos, photographs, and reports concerning a claimant’s physical or mental condition relative to the claim. The Commissioner concluded that section 85.27(2) overrides the work product immunity, thus requiring the disclosure of surveillance materials upon request from a claimant before the claimant is deposed. The district court affirmed. The Supreme Court reversed, holding that section 85.27(2) does not affect privileges and protections related to the litigation process such as the work product doctrine because the statute is limited to health-care-related privileges such as the physician-patient privilege. Remanded. View "Iowa Ins. Inst. v. Core Group of the Iowa Ass’n for Justice" on Justia Law

Employee was injured while working for Employer. Employee filed a workers’ compensation claim and submitted a report from a physician from whom she received an examination that was not authorized by Employer. The deputy workers’ compensation commissioner concluded that Employee suffered a permanent partial disability to her back and taxed as a cost against Employer the expense of the examination and report under the administrative rule governing the assessment of costs in a hearing. The district court affirmed, holding that the reimbursement was proper. The court of appeals reversed, concluding that the reimbursement would be inconsistent with Iowa Code 85.39. The Supreme Court affirmed, holding that the commissioner may not tax the fees of a physician arising from the evaluation of an employee done outside the process set forth in section 85.39 as “costs incurred in the hearing” when the employee submits a written report of the evaluation at the hearing. View "Des Moines Area Reg’l Transit Auth. v. Young" on Justia Law