Justia Labor & Employment Law Opinion Summaries

John Goodpaster worked as a customer service manager for Schwan’s Home Service, Inc., the largest home delivery frozen foods company in the nation, at Schwan’s Des Moines location. Goodpaster’s duty was to sell and deliver company products, and a basic requirement of Goodpaster’s job was that he drive a commercial vehicle. When Goodpaster began experiencing medical problems, his sales began to decrease, and he was eventually terminated. Goodpaster sued Schwan’s under the Iowa Civil Rights Act (ICRA) for disability discrimination and retaliation, claiming his employment was terminated because he had multiple sclerosis. The district court granted summary judgment in favor of Schwan’s. The Supreme Court reversed, holding (1) multiple sclerosis is a disability contemplated by the ICRA; and (2) a genuine issue of material fact existed regarding whether Goodpaster was qualified to perform the essential functions of his position. Remanded. View "Goodpaster v. Schwan's Home Serv., Inc." on Justia Law

AFSCME Iowa Council 61, which represents certain State employees in collective bargaining, entered into negotiations with the State regarding its 2013-2015 collective bargaining agreement. The State proposed deleting certain contract provisions from the existing contract that addressed outsourcing of work performed by public employees. AFCME disputed the State’s classification of this provision as a permissive bargaining subject, arguing that the provision was a procedure for staff reduction and therefore a mandatory subject of bargaining. The Iowa Public Employment Relations Board (“PERB”) concluded that the predominate purpose of the proposal was to designate a process for implementing a staff reduction due to outsourcing, and therefore, the proposal was subject to mandatory bargaining. The district court reversed. The Supreme Court affirmed in part and reversed in part, holding (1) to the extent the primary purpose of the proposal was to preclude the State from reducing staff in response to outsourcing, it was a permissive rather than a mandatory subject of bargaining; but (2) if, on remand, PERB determined that the State was permitted to reduce employment resulting from outsourcing, then the proposal may be found to be a mandatory subject of bargaining. View "AFSCME Iowa Council 61 v. State, Dep't of Admin. Servs." on Justia Law

After taking self-care leave under the Family and Medical Leave Act (FMLA), Plaintiff was terminated from her employment with the State. A jury found the State terminated Plaintiff in violation of her rights under the FMLA. The district court awarded Plaintiff money damages and ordered the State to reinstate Plaintiff to her former position. The State appealed and successfully requested a stay of Plaintiff’s reinstatement pending the outcome of the appeal. The Supreme Court subsequently held that sovereign immunity precluded Plaintiff’s judgment for money damages against the State. On remand, the district court once again ordered Plaintiff reinstated and awarded lost wages and benefits from the date of the original reinstatement order, concluding that the State had waived its sovereign immunity by seeking a stay of the reinstatement order and promising to pay Plaintiff’s interim wages and benefits if the Court affirmed the original order. The Supreme Court affirmed, holding (1) Plaintiff’s pleadings were sufficient to preserve her right to Ex parte Young remedies, and the parties litigated the reinstatement remedy by consent; and (2) the Eleventh Amendment to the U.S. Constitution does not bar an award of wages and benefits for the period during which a reinstatement order was stayed. View "Lee v. State" on Justia Law

In 2005, James House began working as a commercial truck driver for Mike Brooks, Inc. In 2007, House slipped and fell in any icy parking lot while retrieving cargo and injured his back. House returned to work but experienced regular back pain after doing so. In 2008, House pushed open a heavy door and experienced an increase in pain and a burning sensation in the area of his 2007 back injury. House filed a petition for workers’ compensation benefits. A deputy commissioner found House had sustained a permanent total disability (PTD) and rejected Brooks’ contention that the 2008 incident resulted in an injury distinct from the 2007 injury. The commissioner affirmed the award of PTD benefits, including the finding that House’s injury and resulting PTD were caused by the 2007 incident. The district court affirmed. The court of appeals reversed, concluding that the commissioner’s finding of causation was not supported by substantial evidence. The Supreme Court vacated the court of appeals and affirmed the district court’s decision, holding that substantial evidence supported the causation finding made by the commissioner. View "Mike Brooks, Inc. v. House" on Justia Law

As a condition of her employment, Employee signed an agreement to arbitrate claims with Employer. Employee later filed a complaint with the Iowa Civil Rights Commission (ICRC), alleging that Employer had discriminated against her because of her pregnancy. The ICRC subsequently filed a statement of charges with the Iowa Department of Inspections and Appeals (DIA). Employer filed a motion to dismiss the ICRC’s charges or, in the alternative, compel arbitration. The DIA denied Employer’s motion on the ground that ICRC was not a party to the arbitration agreement and, consequently, not bound by it. On judicial review, the district court remanded instructions for the ICRC to dismiss the matter pending arbitration by the parties, concluding that the Federal Arbitration Act (FAA) preempted state law. The Supreme Court reversed, holding the FAA did not require arbitration of this proceeding because it was brought by an entity that was not bound to arbitrate under generally applicable principles of contract law, where the ICRC was not a party to the agreement and its interest was not derivative of Employee’s. View "Rent-A-Center, Inc. v. Iowa Civil Rights Comm'n" on Justia Law

Plaintiff, an employee of BNSF Railway Company, was injured due to the railroad’s negligence. Because of his injury, Plaintiff was no longer able to work at his job. Plaintiff, who was almost fifty-nine years old, sued BNSF under the Federal Employers’ Liability Act (FELA) seeking $755,000 in economic damages, claiming that he planned to work until he was sixty-six years old. BNSF, in turn, attempted to introduce evidence that Plaintiff was eligible to retire on full benefits at age sixty and that most railroad employees in Plaintiff’s position retire at age sixty. The district court excluded the railroad’s evidence based on its reading of the federal collateral source rule applicable to FELA cases. A jury subsequently awarded $1.25 million, including pain and suffering, to Plaintiff. The Supreme Court reversed and remanded for a new trial on damages, holding (1) when a railroad employee makes a claim of lost earning capacity based on a hypothetical retirement age, federal law does not bar the introduction of evidence as to when railroad employees in the plaintiff’s position typically retire; and (2) BNSF was improperly precluded from presenting this excluded statistical evidence, and the error was not harmless. View "Giza v. BNSF Ry. Co." on Justia Law

Claimant, an undocumented worker, underwent surgery in 2007 to correct work-related hernias. Claimant returned to work, but in 2008 Employer terminated Claimant's employment. In 2007, Claimant filed for workers' compensation benefits. A deputy commissioner awarded running healing period benefits from the date of the work-related injury until Claimant reached maximum medical improvement. The Iowa Workers' Compensation Commissioner affirmed the deputy's decision. The district court affirmed, holding that substantial evidence supported the running award of healing period benefits, the Commissioner was correct in starting healing period benefits at a date prior stipulated date, and Claimant's return to work did not cut off any of her benefits. The Supreme Court affirmed in part and reversed in part, holding (1) an undocumented worker is entitled to healing period benefits under the Iowa Workers' Compensation Act; (2) the district court did not err in affirming on the issues of substantial evidence and the starting date of Claimant's benefits; and (3) Claimant was not entitled to healing period benefits while she was working. Remanded. View "Staff Mgmt. v. Jimenez" on Justia Law

Plaintiff was terminated from his employment as dean of students and vice president of student services at the University of Iowa by the University's president, Sally Mason, after a report from the Stolar Partnership (Stolar), a law firm retained by the Board of Regents (Regents) to investigate the University's response to a sexual assault of a student athlete by other student athletes, came out highly critical of Plaintiff. Plaintiff sued the University, Mason, the Regents, and Stolar for wrongful termination and related causes of action. The district court granted summary judgment for Defendants on all claims. The Supreme Court affirmed, holding that the district court did not err (1) in denying Plaintiff's motion to compel discovery of written communications between Stolar and the Regents based on its finding that the attorney-client privilege protected the communications from disclosure; and (2) in granting summary judgment to Defendants on Plaintiff's various claims. View "Jones v. Univ. of Iowa" on Justia Law

After Plaintiff, an at-will employee, reported a forgery on the part of supervisors at an assisted living facility, the facility terminated Plaintiff's employment. The Department of Inspections and Appeals later concluded that certain state-mandated documents relating to the facility's dementia training program had been forged. Plaintiff subsequently filed an action against the facility for wrongful discharge. The jury returned a verdict for Plaintiff, finding the facility terminated her in retaliation for whistleblowing and a willful and wanton disregard for the rights or safety of others. The jury also awarded punitive damages. The court of appeals (1) affirmed the court's finding that the public-policy exception to the at-will employment doctrine protected Plaintiff's employment from retaliatory termination, but (2) reversed the court's decision to submit the issue of punitive damages to the jury. The Supreme Court affirmed, holding (1) an employer's retaliatory discharge of Plaintiff violated public policy; and (2) the district court should not have submitted the punitive damages claim to the jury because at the time of Plaintiff's discharge, the Court did not recognize a public-policy exception to the at-will employment doctrine based upon a violation of administrative rules. View "Dorshkind v. Oak Park Place of Dubuque II, LLC" on Justia Law

Dentist fired his long-time female dental assistant (Employee) at the request of his wife after she discovered Dentist and Employee had been texting. Wife claimed Employee "was a big threat" to the marriage. Employee subsequently brought this action against Dentist, alleging that he discriminated against her on the basis of sex. The district court granted summary judgment for Dentist, concluding that Employee was not fired because of her gender but because she was a threat to Dentist's marriage. The Supreme Court affirmed, holding that Dentist did not engage in unlawful gender discrimination in violation of the Iowa Civil Rights Act when he fired Employee at the request of his wife. View "Nelson v. Knight" on Justia Law