Justia Iowa Supreme Court Opinion Summaries

A corporation does not have family members and therefore cannot qualify for the family-member exception to the employee-numerosity requirement in the Iowa Civil Rights Act (ICRA).Plaintiff worked for Defendant, a small insurance agency, and alleged that she was sexually harassed by her supervisor, the sole owner’s husband. Defendant, a subchapter S corporation, employed the owner, the owner’s husband and two other family members, Plaintiff, and another nonfamily member. Defendant moved for summary judgment on the ICRA claims on the grounds that it employed fewer than four individuals, not counting the family members. The district court denied summary judgment, concluding that a corporate employer is ineligible for the family-member exception to the ICRA contained in Iowa Code 216.6(6)(a). The court of appeals affirmed. The Supreme Court affirmed, holding that Defendant could not avail itself of the family-member exception. View "Cote v. Derby Insurance Agency, Inc." on Justia Law

The Supreme Court reversed the order of the district court awarding Plaintiff her attorney fees and expenses.In this action alleging wrongful discharge and retaliation, the district court entered judgment in favor of Plaintiff. The district court awarded Plaintiff fees and expenses. After several appeals, the court ultimately awarded Plaintiff a total sum of $223,792. The Supreme Court set the fee award at $241,700 and the expense award at $5664, holding (1) the district court did not abuse its discretion by using Plaintiff’s attorneys’ currently hourly rates or by using the percentage reduction method to reduce the total requested fees and expenses; but (2) the district court abused its discretion in the manner it used the percentage reduction method and by not awarding Plaintiff any of the expenses she requested in her application for fees and expenses. View "Lee v. State" on Justia Law

This case involved claims brought against various state officials for damages related to public employment. Plaintiff was an Iowa Workers’ Compensation Commissioner. At issue in this interlocutory appeal were four counts alleging violation of due process and equal protection provisions of the Iowa Constitution. The district court granted summary judgment for Defendants on these claims finding that there are no private causes of action for violations of the Iowa Constitution. The Supreme Court reversed in part and affirmed in part, holding that Defendants were not entitled to summary judgment on Counts VI and VII where (1) the equal protection clause of the Iowa Constitution is self-executing; (2) classic preempt doctrine does not apply to the question of whether a Bivens-type damage remedy is available through the Iowa Constitution; and (3) the different nature of the interests protected weighs in favor of allowing a Bivens-type claim to go forward against Defendants. View "Godfrey v. State" on Justia Law

In this employment discrimination case, prejudicial errors in four jury instructions required a new trial.Plaintiff filed claims against her former employer, alleging sexual harassment and retaliation under the Iowa Civil Rights Act (ICRA). The jury returned a verdict for Plaintiff on both counts and awarded damages in the amount of $1.4 million. Employer then filed a motion for new trial, which the district court denied. The Supreme Court reversed, holding (1) workers may bring a direct-liability negligence claim under the ICRA against an employer for supervisor harassment, but the plaintiff must prove that the employe knew or should have known of the harassment and failed to take prompt and appropriate remedial action to end it; (2) the district court did not abuse its discretion in admitting expert testimony on legal standards; but (3) the district court misinstructed the jury in four jury instructions, necessitating a new trial. View "Haskenhoff v. Homeland Energy Solutions, LLC" on Justia Law

A civil service employee may enter into a valid last-chance agreement, which remains subject to principles of contract law, and the civil service commission need not sanction the agreement for it to be effective.A municipal firefighter pled guilty to domestic abuse assault. The municipality offered to discipline him instead of terminating his employment but required that the firefighter agree that the municipality have the discretion to terminate him immediately and without appeal if he violated the related no-contact order. The firefighter agreed to the proposal and signed a written "last-chance agreement." One year later, the firefighter violated the no-contact order, and the municipality terminated the firefighter’s employment in reliance on the agreement. The firefighter attempted to appeal, but the civil service commission declined to hear the appeal. The district court, however, concluded that the last-chance agreement was invalid because the commission had not approved or reviewed it before the parties entered into it. The Supreme Court reversed, holding that the last-chance agreement in this case was valid and enforceable. View "Whitwer v. Civil Service Commission of the City of Sioux City" on Justia Law

A Dubuque civil rights ordinance exempts “any employer who regularly employs less than four individuals.” The former employee of Appellant, a landscaper whose hiring needs fluctuate seasonally, filed a complaint with the Dubuque Human Rights Commission (DHRC) alleging discrimination in violation of the ordinance. The DHRC found in favor of the employee. Appellant filed a petition for judicial review arguing that it did not employ the requisite number of employees to be subject to the ordinance. The district court affirmed the DHRC’s decision and upheld the damages awarded to the employee. The Supreme Court affirmed, holding (1) the DHRC correctly determined that Appellant “regularly employed” the requisite four or more individuals during its landscaping season; (2) the DHRC properly used a payroll approach and rejected Appellant’s proposed twenty-week test; and (3) substantial evidence supported the DHRC’s findings. View "Simon Seeding & Sod, Inc. v. Dubuque Human Rights Commission" on Justia Law

Plaintiff, who was paralyzed in an accident during a work accident, filed a petition seeking a determination of permanent total disability (PTD) and also sought partial commutation of benefits in a lump sum. Defendant, the workers’ compensation insurer, disputed whether Plaintiff was PTD and resisted the commutation, although it continued to pay full weekly PTD benefits and explore settlement. The Iowa Workers’ Compensation Commissioner granted Plaintiff’s petition for partial commutation. Plaintiff then sued Defendant for first-party bad faith. On summary judgment, the district court determined that Defendant acted in bad faith. The jury awarded punitive and compensatory damages at a ratio of 88:1. The Supreme Court (1) reversed the judgments for compensatory and punitive damages, holding that, while Defendant knew or should have known it lacked any reasonable basis to dispute Plaintiff’s PTD status, the district court erred in ruling that Defendant was in bad faith as a matter of law for resisting the commutation; and (2) the district court properly denied Plaintiff an award of attorney fees incurred in prosecuting the bad-faith action. View "Thornton v. American Interstate Insurance Co." on Justia Law

Rosalva Ochoa was terminated from her employment with JBS Swift & Company for absenteeism. Ochoa filed two workers’ compensation petitions against Swift and its workers’ compensation carrier, alleging a cumulative left groin injury and a cumulative injury to the neck and right shoulder during the course and scope of her employment. A workers’ compensation deputy commissioner ordered Swift to pay Ochoa permanent partial disability benefits and permanent total disability benefits, but the award eliminated what would otherwise amount to overlapping partial disability benefits and total disability benefits. The workers’ compensation commissioner concluded that Ochoa’s permanent partial disability payments should not have terminated as of the date when her permanent total disability payments commenced, which resulted in Ochoa receiving more than six years of overlapping weekly benefits. The district court and court of appeals affirmed. The Supreme Court affirmed, holding that Iowa workers’ compensation law does not prohibit an employee from collecting both permanent partial disability benefits and permanent total disability benefits at the same time when the employee suffers successive injuries at the same workplace. View "JBS Swift & Co. v. Ochoa" on Justia Law

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