On June 30, the Iowa Supreme Court clarified the necessary elements a plaintiff must prove to succeed in a claim for wrongful discharge in violation of public policy. Specifically, the Court considered whether or not a plaintiff needs to prove that her employer lacked a legitimate business justification for her termination. Ultimately, the Court held that a plaintiff is not required to make such a showing.
The Court grounded its decision in Iowa’s long held requirement that a plaintiff show her protected conduct was the determining factor for her termination, rather than merely a motivating factor. This higher standard of “but for” causation means that even if a plaintiff’s employer had a legitimate business justification to terminate her, a plaintiff could prevail as long as she could show that the factor that “tipped the scales” was the fact that the plaintiff engaged in protected conduct. Thus, the mere fact that an employer had some legitimate business reasons to fire an employee is not always a sufficient defense to a wrongful discharge claim.
This ruling does not mean that an employer’s evidence of a legitimate business reason is irrelevant. Such evidence is still relevant for the employer to convince the fact finder that the business reasons supporting the termination were so strong as to defeat the conclusion that the protected conduct was the determining factor.
Finally, the Court carved out an exception to the general rule for an employer to use an “overriding business justification” as an affirmative defense. This exception applies to a situation in which an employer asserts a business justification rooted in a public policy that competes with the plaintiff’s protected conduct that is protected by another public policy. In those circumstances, the employer will succeed if it can show its public policy “trumps” the public policy that protects the plaintiff’s conduct.
See the full opinion: Terri Aleta Rivera v. Woodward Resource Center and State of Iowa, No. 14-0194, 2015 WL 3958720 (Iowa June 30, 2015).