Nyemaster Goode, P.C.

More on Ackelson v. Manley Toy Direct, L.L.C.

By Frank Harty

In Ackelson v. Manley Toy Direct, L.L.C., the Iowa Supreme Court clearly held that punitive damages may not be awarded in employment claims brought under the Iowa Civil Rights Act. The decision reaffirmed the Court’s 1986 holding in Chauffeurs Teamsters & Helpers, Local Union No. 238 v. Iowa Civil Rights Commission. The Court noted that the plaintiffs argued that the McElroy decision overturning Smith signaled that Chauffeurs was no longer good law. The Court disagreed and distinguished the two decisions.

In Ackelson, the Court discussed the status of the law in other jurisdictions and noted a national trend to allow punitive damages in civil rights claims. The Court also discussed the public policy considerations on both sides of the issue. In the end, however, the decision turned upon time-honored concepts of stare decisis and legislative assent.

The Court noted that its job is to interpret the law as written by the legislature. The Court also noted that it had on numerous occasions held that for employment claims, punitive damages are not available under the Iowa Civil Rights Act. The Court noted the Iowa legislature has amended the Act numerous times since the issuance of these decisions. The legislature is presumed to know about the Court’s pronouncements. Its failure to revise the statute indicates its agreement with the approach taken by the Court.

In the end, the Court clearly indicated that if there were going to be any change it would have to be made by the Iowa legislature.


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