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Iowa Supreme Court: Punitive Damages are Not Available Under the Iowa Civil Rights Act

By Ryan Koopmans and Tom Cunningham

Nyemaster Goode attorneys Frank Harty, Debra Hulett, and Mary Funk of our Des Moines office and Fran Haas of our Cedar Rapids office achieved a significant victory this morning in the Iowa Supreme Court. A unanimous Court ruled in Ackelson v. Manley Toy Direct, Chief Justice Cady writing, that punitive damages cannot be awarded under the Iowa Civil Rights Act. In doing so, the Court reaffirmed the same ruling from its 1986 decision in Chauffeurs, Teamsters & Helpers, Local Union No. 238 v. Iowa Civil Rights Commission. The plaintiffs in this case–and almost every other discrimination case in Iowa over the last five years–had argued that Chauffeurs was out of style, and that the Supreme Court itself had weakened the no-punitive-damages rule in later rulings.

Not so, said the seven-justice court. Citing Manley Toy’s “strong countervailing argument,” Chief Justice Cady noted that the Iowa Supreme Court has, on several occasions, mentioned the no-punitive-damages rule (even if in dicta), and yet the Iowa legislature has done nothing to amend the statute (though it has amended other parts of the Iowa Civil Rights Act).

Despite the Court’s 1986 decision, the plaintiff’s employment bar in Iowa has been extremely aggressive in raising this issue in many ICRA cases throughout the state over the last several years seeking to get the earlier ruling overturned. A comprehensive analysis of the opinion will follow in another blog post



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