Justia Labor & Employment Law Opinion SummariesArticles Posted in Iowa Supreme Court
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
Roland v. Annett Holdings, Inc.
The Supreme Court reversed the ruling of the district court certifying a class action of employees with pending workers' compensation claims, holding that the district court abused its discretion by certifying this case as a class action.Employee filed this civil action on behalf of himself and other "similarly situated" employees who signed a memorandum of understanding (MOU) as a condition of employment providing for short-term light duty and treatment in Des Moines after sustaining a work-related injury. Before the instant case was filed, an Iowa court determined the MOU as applied to Employee violated Iowa Code 85.18 and 85.27(4). The district court certified the case as a class action. The Supreme Court reversed, holding that because the commonality requirement was lacking, individual issues predominated over common ones, and because workers' compensation claims must be resolved by the workers' compensation commission before judicial review, the district court erred in certifying this case as a class action. View "Roland v. Annett Holdings, Inc." on Justia Law
Thornton v. American Interstate Insurance Co.
The Supreme Court reversed the judgment of the district court awarding Plaintiff compensatory and punitive damages in his action for first-party bad faith in connection with a workers' compensation claim, holding that the compensatory award must be reduced and that, under the federal Due Process Clause, the maximum amount of punitive damages that may be awarded under the facts of this case was $500,000.Plaintiff, who was severely injured at work, brought this lawsuit alleging that a workers' compensation insurance carrier acted in bad faith to delay the receipt of benefits to which Plaintiff was entitled. On retrial, the jury returned a verdict in favor of Plaintiff for $382,000 in compensatory damages and $6,750,000 in punitive damages. The Supreme Court reversed, holding (1) Plaintiff failed to offer substantial evidence to support his claim that the insurance carrier engaged in bad faith in connection with an alleged delay in acquisition of a replacement wheelchair; (2) with respect to the permanently and totally disabled bad-faith claim, the evidence supported actual damages of no more than $58,452,42; and (3) the maximum amount of punitive damages that may be awarded in this case is $500,000. View "Thornton v. American Interstate Insurance Co." on Justia Law
Sladek v. Employment Appeal Board
The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court upholding the final agency action of the Employment Appeal Board (EAB) denying unemployment benefits, holding that substantial evidence supported the EAB's determination that Employee voluntarily quit.Employee was employed with a temporary employment agency. The agency informed Employee by phone that the workplace where she had been assigned was ending her assignment, after which Employee hung up the phone. Thereafter, Employee applied for unemployment benefits and did not attempt to resume contact with the agency for almost five weeks. In denying benefits, the EAB determined that Employee voluntarily quit her employment without good cause attributable to the employer. The district court and court of appeals affirmed. The Supreme Court affirmed, holding (1) the EAB's determination that Employee voluntarily quit was supported by substantial evidence; and (2) substantial evidence supported the EAB's finding that Employee did not meet the safe harbor in Iowa Code 96.5(1)(j)(1) relating specifically to temporary employees of temporary employment firms. View "Sladek v. Employment Appeal Board" on Justia Law
Ferguson v. Exide Technologies, Inc.
The Supreme Court reversed the order of the district court denying Defendants' motion for judgment notwithstanding the verdict on Plaintiff's claim for the common law tort of wrongful discharge in violation of public policy and affirmed the district court's rulings on Plaintiff's wrongful discharge claim based in a violation of Iowa Code 730.5, holding that a common law wrongful discharge claim was not available.Plaintiff brought a claim under section 730.5, which provides civil remedies against employers for violating the workplace drug-testing provisions, and further asserted a claim for wrongful discharge in violation of public policy. Defendant moved for summary judgment, arguing that the common law claim was preempted by the civil case of action provided under the statute. The district court denied the motion and granted summary judgment for Plaintiff. After a trial on the common law wrongful discharge claim the jury awarded Plaintiff damages. The Supreme Court reversed in part, holding (1) the civil cause of action provided by section 730.5 is the exclusive remedy for a violation of section 730.5; and (2) the portions of the jury's award that would be available under section 730.5 are upheld. View "Ferguson v. Exide Technologies, Inc." on Justia Law
Hedlund v. State
The Supreme Court affirmed in part and reversed in part the order of the district court granting summary judgment to Defendants on all claims in this employment case, holding (1) Plaintiff's direct civil action under Iowa Code 70A.28(5), the whistleblower statute, is not precluded by the availability of an administrative remedy; and (2) the district court correctly granted summary judgment on Plaintiff's claims of age discrimination and intentional infliction of emotional distress.Specifically, the Court held (1) section 70A.28(5) expressly creates an independent cause of action in the alternative to administrative remedies under Iowa Code chapter 17A, and therefore, the district court erred when it determined that judicial review following the administrative process was the exclusive means to seek redress for alleged retaliation against a whistleblower; (2) the district court did not err in determining that Plaintiff failed to present sufficient evidence from which a reasonable jury could infer age discrimination was the real reason for Plaintiff's termination; and (3) the district court did not err in granting summary judgment on Plaintiff's intentional infliction of emotional distress claim because none of Defendants' conduct was sufficiently egregious to satisfy the "outrageousness" prong. View "Hedlund v. State" on Justia Law
Hawkins v. Grinnell Regional Medical Center
In this case brought by a former employee alleging discrimination and retaliation, the Supreme Court reversed the judgment of the district court entering judgment on a jury verdict for Plaintiff, awarding him back pay, emotional distress damages, front pay and attorney fees, holding that the district court erred in admitting hearsay, and the hearsay was not harmless.Plaintiff, a terminated employee, brought this action against his former employer and the employer's agents under the Iowa Civil Rights Ac, alleging that Defendants discriminated against him because of his age and his status as a cancer patient and retaliated against him due to his refusal to retire or quit. The jury entered a verdict for Plaintiff. The Supreme Court reversed and remanded the case for a new trial, holding that the district court erred in admitting hearsay and the record failed to rebut the presumption of prejudice associated with the admitted hearsay evidence. View "Hawkins v. Grinnell Regional Medical Center" on Justia Law
Ortiz v. Loyd Roling Construction
The Supreme Court reversed the decision of the district court holding that a copy of a petition for judicial review sent by email to opposing counsel failed to comply with Iowa Code 17A.19(2), which imposes a jurisdictional requirement for the petitioner in an action for judicial review to timely mail a copy of the petition to attorneys for all the parties in the case, holding that emailing between attorneys in Iowa satisfies the jurisdictional requirement of the statute.Petitioner filed a petition for judicial review after the Iowa Workers' Compensation Commissioner issued a decision in a contested case proceeding against Loyd Ruling Construction. Loyd Roling filed a motion to dismiss the petition for judicial review, arguing that the district court lacked jurisdiction because Petitioner's attorney did not mail the copy of the petition through the postal system until more than ten days after the petition was filed, as required by section 17A.19(2). The district court agreed and dismissed the petition, concluding that electronic mailing did not constitute substantial compliance with the statute. The Supreme Court reversed, holding that the service requirement under the statute is satisfied when a lawyer emails a copy of the petition to opposing counsel. View "Ortiz v. Loyd Roling Construction" on Justia Law
United Electrical, Radio & Machine Workers of America v. Iowa Public Employment Relations Board
The Supreme Court affirmed the judgment of the district court interpreting the 2017 amendments to Iowa Code chapter 20, the Public Employment Relations Act, limiting the mandatory subjects of collective bargaining and the matters an arbitrator may consider if the dispute enters binding arbitration, holding that the Iowa Public Employment Relations Board (PERB) and the district court correctly interpreted the amendments.A union sought a declaratory order from PERB and then judicial review of the declaratory order seeking to clarify certain provisions in the amendments. The Supreme Court affirmed the judgment of the district court affirming PERB's decision, holding (1) "base wages" under Iowa Code 20.9(1) means the floor level of pay for each job before upward adjustments such as for job shift or longevity; and (2) the term "past collective bargaining agreement" in the context of Iowa Code 20.22(10)(b)(1) allows an arbitrator to consider the existing collective bargaining agreement but not ones that came before. View "United Electrical, Radio & Machine Workers of America v. Iowa Public Employment Relations Board" on Justia Law