Justia Labor & Employment Law Opinion SummariesArticles Posted in Iowa Supreme Court
Godfrey v. State
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
Rumsey v. Woodgrain Millwork, Inc.
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
Woods v. Charles Gabus Ford, Inc.
The Supreme Court affirmed in part and reversed in part the judgment of the district court dismissing Plaintiff's complaint alleging that Defendant, his employer, did not substantially comply with Iowa Code 730.5(15) when it drug tested him and then terminated him after he tested positive for methamphetamine, holding that equitable relief was appropriate based on the facts of this case.After Plaintiff was randomly selected for a drug test the lab technician rejected Plaintiff's first sample for being insufficient. The second sample tested positive for methamphetamine. Following Plaintiff's termination, Defendant sent Plaintiff a letter informing him of the drug test results and his right to get a confirmatory test. Plaintiff then brought this complaint alleging that the letter did not substantially comply with section 730.5. The district court dismissed the petition. The Supreme Court affirmed in part and reversed in part, holding that Defendant failed to substantially comply with section 730.5(7)(j)(1) when it failed to include the cost of a retest in its notice to Plaintiff. View "Woods v. Charles Gabus Ford, Inc." on Justia Law
Dix v. Casey’s General Stores, Inc.
The Supreme Court affirmed the judgment of the district court concluding that two of Employer's employees were improperly classified as engaged in safety-sensitive positions so that they should never have been drug tested and were entitled to relief and that two other employees were not aggrieved by Employer's actions in attempting to comply with the statutory requirements, holding that there was no error.Employer in this case amended its drug-testing policy to allow for unannounced random drug testing. Plaintiffs, three employees who tested positive and were terminated and a fourth who failed to provide an adequate sample, brought this action under the civil remedies provision of Iowa Code 730.5 arguing that Employer failed to follow statutory requirements involving workplace drug testing. The district court granted relief to two of the four plaintiffs. The Supreme Court affirmed, holding (1) two of the employees should not have been tested under Employer's testing program and were entitled to relief; and (2) the other two employees were not entitled to relief. View "Dix v. Casey's General Stores, Inc." on Justia Law
Iowa Ass’n of Business & Industry v. City of Waterloo
The Supreme Court affirmed in part and reversed in part the judgment of the district court finding that a 2019 Waterloo "ban the box" ordinance was not preempted, holding that the ordinance was preempted to the extent that it purported to regulate a term and condition of employment.In 2017, the legislature adopted a statute, codified at Iowa Code 364.3(12)(a), that prohibits cities from adopting or administering an ordinance providing for any terms or conditions of employment exceeding or conflicting with state or federal law requirements relating to certain employment issues. In 2019, the City of Waterloo enacted the ordinance at issue, which regulated the time when an employer can inquire into a prospective employee's criminal history. The district court concluded that no part of the ordinance was preempted. The Supreme Court reversed in part, holding (1) the ordinance was preempted to the extent it purported to regulate whether an employer can consider an employee's criminal history at all; and (2) the ordinance was not preempted where it only regulated timing because that was not a term or condition of employment. View "Iowa Ass’n of Business & Industry v. City of Waterloo" on Justia Law
Williams v. Bullock
The Supreme Court affirmed the ruling of the district court ruling that Plaintiff's employer had complied with Iowa Code 35C.6 when it terminated the employment of Plaintiff, a military veteran, from his job as a police officer at the University of Iowa's (UI) Department of Public Safety (DPS), holding that the district court did not err.Plaintiff was charged with misconduct after he violated DPS policies. Following arbitration, Plaintiff was terminated and was later reinstated without back pay. Plaintiff filed a petition for writ of certiorari alleging that DPS violated section 35C.6 in his initial termination. The district court ruled that DPS had complied with section 35C.6 as interpreted in Kern v. Saydel Community School District, 637 N.W.2d 157 (Iowa 2001). The Supreme Court affirmed, holding (1) this Court declines to overrule Kern; and (2) the district court correctly determined that the State complied with Iowa Code 35C.6 in terminating Plaintiff. View "Williams v. Bullock" on Justia Law
Andrew v. Hamilton County Public Hospital
The Supreme Court reversed the judgment of the district court denying Hamilton County Public Hospital's motion for summary judgment concerning Plaintiff's defamation claim and Iowa Wage Payment Collection Law (IWPCL) claim, holding that Plaintiff's defamation and statutory wage claims failed.Plaintiff, a general surgeon, was employed by the hospital. After an investigation, Plaintiff's employment through a for-cause provision in his contract was terminated. The hospital subsequently made two reports to the Iowa Board of Medicine and the National Practitioner Data Bank. Plaintiff then brought this action. The hospital moved for summary judgment on the defamation and IWPCL claims, but the district court denied the motion. The Supreme Court reversed on interlocutory appeal, holding (1) Plaintiff's defamation claim failed because the challenged portions of the reports were nonactionable opinions; and (2) Plaintiff's statutory wage claim failed because he did not perform work for which he was not paid. View "Andrew v. Hamilton County Public Hospital" on Justia Law
Terry v. Dorothy
The Supreme Court affirmed the ruling of the district court dismissing an employee's gross negligence claim against a coemployee, holding that settlement documents submitted to and approved by the workers' compensation commissioner extinguished the employee's gross negligence claim.Plaintiff, an employee of Lutheran Services in Iowa (LSI) was attacked by one of LSI's clients, causing injuries. Plaintiff filed a workers' compensation claim against LSI and its workers' compensation carrier. The parties settled, and the two settlement documents were approved by the Iowa Workers' Compensation Commissioner. Plaintiff subsequently filed a petition in district court seeking to recover damages from Defendant, Plaintiff's supervisor when he worked at LSI, on a theory of gross negligence. Defendant moved to dismiss the action, relying on release language in the settlement documents. The district court granted summary judgment for Defendant on both contract and statutory grounds. The court of appeals reversed, concluding that a settlement with the commissioner did not release a common law claim of gross negligence against a coemployee. The Supreme Court vacated the court of appeals' judgment and affirmed the district court's summary judgment, holding that the district court properly ruled that, as a matter of contract, the language in the terms of settlement extinguished Plaintiff's gross negligence claim. View "Terry v. Dorothy" on Justia Law
Logan v. Bon Ton Stores, Inc.
The Supreme Court reversed the judgment of the district court dismissing Appellant's petition for judicial review, holding that timely faxing a petition for judicial review to the opposing party's counsel, where the petition is actually received and no prejudice results, constitutes substantial compliance under Iowa Code 17A.19(2).Appellant filed four petitions with the Iowa Workers' Compensation Commission against Respondents, her employer and its workers' compensation insurance carrier, alleging that she received several workplace injuries. The commissioner largely denied the petitions. Appellant then filed a pro se petition with the district court seeking judicial review. The petition was electronically filed, and Appellant faxed copies the same day to Respondents and the workers' compensation commission. The district court granted Respondents' motion to dismiss, concluding that Appellant's sending of a fax of her petition was not substantial compliance with the requirements of section 17A.19(2). The Supreme Court reversed, holding that Appellant substantially complied with the service requirements in section 17A.19(2). View "Logan v. Bon Ton Stores, Inc." on Justia Law
Gumm v. Easter Seal Society of Iowa, Inc.
The Supreme Court affirmed the order of the district court denying Claimant's petition for judicial review challenging the decision of the workers' compensation commissioner concluding that Claimant, who was receiving disability benefits for a traumatic injury, could not later recover disability benefits on a separate cumulative injury claim where the cumulative injury was based solely on aggravation of the earlier traumatic injury.Because the three-year statute of limitations for review-reopening had passed Claimant instead brought a separate cumulative injury claim. The commissioner declined to award benefits for the asserted cumulative injury. The district court upheld the commissioner's ruling. The court of appeals reversed, concluding that because Claimant was precluded by the statute of limitations from bringing an original proceeding or review-reopening she could recover by way of a cumulative-injury claim. The Supreme Court reversed, holding that sufficient record evidence sustained the commissioner's finding that Claimant's difficulties were merely the aggravation over time of her original injury and that Claimant did not suffer a distinct and discrete cumulative injury to support additional benefits. View "Gumm v. Easter Seal Society of Iowa, Inc." on Justia Law