Justia Labor & Employment Law Opinion Summaries

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

The Supreme Court affirmed the district court's judgment against the State enforcing a collective bargaining agreement (CBA) between the State and a public employee union, holding that the district court had subject matter jurisdiction and correctly ruled that the State had not withdrawn its offer before the union's acceptance and ratification resulted in an enforceable CBA.The State moved to dismiss or stay the action in favor of administrative proceedings pending at the Public Employment Relations Board arguing no contract was formed after the union accepted the State's pending offer and the union membership voted to ratify the terms . The district court denied the State's motion and then granted the union's motion for summary judgment. The Supreme Court affirmed, holding (1) the State failed to preserve its argument that Iowa Admin. Code R. 621-6.5(3) requires the State to vote to ratify after the union vote; (2) the union's ratification resulted in an enforceable CBA; and (3) the district court's rulings rejecting the primary-jurisdiction and exhaustion doctrines were correct. View "UE Local 893/IUP v. State" on Justia Law

The Supreme Court affirmed the district court's grant of summary judgment in favor of Defendants on Plaintiffs' claim that the 2017 amendments to Iowa Code chapter 20, the Public Employment Relations Act (PERA), violate the equal protection clause of the Iowa Constitution, holding that the 2017 amendments withstood the constitutional challenges.The 2017 amendments resulted in new classifications that made many public employees lose significant statutory bargaining rights compared to other public employees with ostensibly similar jobs. A public employee union and some of its members filed this action against the State and the Public Employment Relations Board (PERB) seeking injunctive and declaratory relief alleging that the amendments violated the equal protection clause of the Iowa Constitution and their right to freedom of association. The district court dismissed the action on summary judgment. The Supreme Court affirmed, holding that the legislative classifications are not so overinclusive or underinclusive as to be unconstitutional and that the amendments do not violate constitutional rights of freedom of association. View "AFSCME Iowa Council 61 v. State" on Justia Law

The Supreme Court affirmed the district court's summary judgment in favor of Defendants on Plaintiffs' claim that the 2017 amendments to Iowa Code chapter 20, the Public Employment Relations Act (PERA), violate the equal protection clause of the Iowa Constitution, holding that the 2017 amendments withstood the constitutional challenges.The 2017 amendments resulted in new classifications that made many public employees lose significant statutory bargaining rights compared to other public employees with ostensibly similar jobs. Two unions representing public school employees filed this action seeking injunctive and declaratory relief against the State, the Iowa Public Employment Relations Board (PERB), and three PERB board members, alleging that the amendments violated the equal protection clause of the Iowa Constitution. The district court dismissed the action on summary judgment. The Supreme Court affirmed, holding that the legislative classifications are not so overinclusive or underinclusive as to be unconstitutional under this Court's rational basis test. View "Iowa State Education Ass'n v. State, Iowa Public Employment Relations Board" on Justia Law

The Supreme Court answered a certified question of Iowa law by holding that, under Iowa law, a common law cause of action for bad faith failure to pay workers' compensation benefits is not available against a third-party claims administrator of a worker's compensation insurance carrier.Plaintiff, who suffered a work-related injury, filed a claim for benefits with the workers compensation commissioner. Plaintiff was denied benefits. Plaintiff later filed a bad faith action against his employer's workers' compensation carrier and its third-party administrator. The action was removed to the federal district court, and the court certified the following question to the Supreme Court: “In what circumstances, if any, can an injured employee hold a third-party claims administrator liable for the tort of bad faith for failure to pay workers’ compensation benefits?” The Supreme Court held that a third-party administrator cannot be sued for bad faith as if it were an insurer. View "De Dios v. Indemnity Insurance Co. of North America" on Justia Law

The Supreme Court affirmed the judgment of the district court granting an employer's workers' compensation insurance carrier's motion to dismiss Plaintiffs' common law tort claim and ruling that Iowa Code 517.5 was constitutional, holding that the statute is not violative of equal protection, inalienable rights, or due process under article I, sections 1, 6, and 9 of the Iowa Constitution.Plaintiffs, employees and former employees of an Iowa manufacturing company, brought this action alleging that the insurance carrier failed to conduct or negligently conducted an insurance inspection at their employer's manufacturing facility, causing serious health problems for Plaintiffs. The insurance carried moved to dismiss the petition under section 517.5, which provides that "no inspection of any place of employment made by insurance company inspectors...shall be the basis for the imposition of civil liability upon the inspector or upon the insurance company..." The district court dismissed the actions after determining that the provision was constitutional. The Supreme Court affirmed, holding that there is no claim for negligent inspection against a workers' compensation carrier. View "Clark v. Insurance Co. State of Pennsylvania" on Justia Law

The Supreme Court reversed the judgment of the district court affirming the decision of the workers’ compensation commissioner declining to award benefits to a fast-food employee who suffered serious head injuries when he fell backwards directly to a tile floor after having a seizure while handling a customer order, holding that there is no blanket rule rendering certain categories of workplace idiopathic falls noncompensable.The commissioner reasoned that idiopathic falls from a standing or walking position to a level floor do not arise out of employment under the workers’ compensation law. The district court affirmed. The Supreme Court reversed, holding (1) whether injuries suffered in an idiopathic fall directly to the floor at a workplace arises out of employment is a factual matter, not a legal one, and the factual question to be determined is whether a condition employment increased the risk of injury; and (2) the commissioner in this case incorrectly treated a factual issue as a legal matter. View "Bluml v. Dee Jay's Inc." on Justia Law