Nyemaster Goode, P.C.

Nyemaster Goode Top 10 List: No. 1 – New Year, New Law? Iowa Supreme Court Decisions in 2014

By Debra Hulett

This term, the Iowa Supreme Court will likely decide appeals in employment-related cases, including cases interpreting the Iowa Civil Rights Act.

In September 2013, the Court heard oral argument in Pippen, et al. v. State of Iowa, et al. This appeal followed a month-long bench trial in a class-action lawsuit. The plaintiffs, individuals that sought employment with or promotion within the State of Iowa’s merit-based employment system, pursued disparate-impact race discrimination claims under Title VII and the Iowa Civil Rights Act based on what the plaintiffs described as aggregate statistical disparities across the employment system as a whole. The plaintiffs were unsuccessful at trial, and on appeal they continue to pursue the disparate-impact discrimination theory that the district court rejected.

In November 2013, the Court heard oral argument in Goodpaster v. Schwan’s Home Service, Inc., et al. The plaintiff, a former employee of the defendant, filed suit against his former employer and former supervisor in Polk County district court, alleging (in part) disability discrimination under the Iowa Civil Rights Act. After the district court granted summary judgment in favor of the defendants, the plaintiff appealed. While the plaintiff presents various arguments on appeal, the plaintiff’s primary argument relates to a legal issue: whether the Iowa Supreme Court should engraft the federal 2008 Americans with Disabilities Act Amendment Act (“ADAAA”) on the Iowa Civil Rights Act. Since the parties raise other arguments, the Court may decide this appeal without reaching that legal issue. But that seems unlikely. This same legal issue was presented to the Court in an earlier certified-question appeal, Stotler v. Delavan, but days before oral argument, the parties notified the Court that the case has been resolved.

Also, in January 2014, the Court will once again consider an appeal in the case Lee v. State of Iowa, et al.—this time without oral argument. In this Family and Medical Leave Act case, filed nearly eight years ago, the plaintiff claimed that the state terminated her employment and retaliated against her because she exercised her rights under the FMLA’s self-care provisions. Lee v. State of Iowa, 815 N.W.2d 731, 734-35 (Iowa 2012). After trial, a jury returned a verdict in the plaintiff’s favor, and the state appealed, in part based on a sovereign immunity argument. Following the U.S. Supreme Court’s decision in Coleman v. Court of Appeals of Maryland, 132 S.Ct. 1327 (2012), the Iowa Supreme Court concluded that “The cloak of immunity granted to the State precludes state employees from suing the state for monetary relief when denied self-care leave under the FMLA,” Lee, 815 N.W.2d at 743, and remanded the case to the district court to determine “what relief granted in its judgment is still available to Lee within the framework of this lawsuit, findings of the jury at trial, and the cloak of immunity protecting the State.” Id. In this appeal, the parties argue over the district court’s rulings on remand.


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