Justia Labor & Employment Law Opinion Summaries

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

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

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

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

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

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

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

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

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

The Supreme Court affirmed the district court's grant of summary judgment dismissing this action filed by a public employee union seeking to enforce a collective bargaining agreement entered into with the Iowa Board of Regents, holding that the Public Employment Relations Board (PERB) acted within its statutory authority in promulgating Iowa Admin. Code R. 621-6.5(3), which has the force of law, and that the district court correctly applied rule 621-6.5(3) to hold the parties had no enforceable collective bargaining agreement (CBA) without the Board's vote to ratify it.The Board moved for summary judgment on the union's action to enforce the CBA, relying on rule 621-6.5, which requires the Board to meet to vote to accept a tentative voluntary agreement ratified by the union before the contract becomes effective. The union argued that the agency rule was invalid because it imposed a ratification requirement not included in Iowa Code 20.17(4). The district court upheld the validity of the agency rule and dismissed the union's enforcement action. The Supreme Court affirmed, holding (1) rule 621-6.5(3) is valid; and (2) therefore, no enforceable agreement was reached without the requisite vote by the Board to approve the CBA. View "Service Employees International Union, Local 199 v. State" on Justia Law