wrongful discharge claim in Iowa

2013Fitzgerald, 613 N.W.2d at 283 (citations omitted); accord Lloyd v. Drake Univ., 686 N.W.2d 225 , 230–31 (Iowa 2004) (rejecting a wrongful- discharge claim lodged by a security guard who was fired after forcibly restraining a student suspected of assault because the asserted public policy against crime is generalized, not “clearly defined”).

2013Fitzgerald, 613 N.W.2d at 283 (citations omitted); accord Lloyd v. Drake Univ., 686 N.W.2d 225, 230-31 (Iowa 2004) (rejecting a wrongful-discharge claim lodged by a security guard who was fired after forcibly restraining a student suspected of assault because the asserted public policy against crime is generalized, not “clearly defined”).

2015See, e.g., Dorshkind v. Oak Park Place of Dubuque II, L.L.C., 835 N.W.2d 293 , 303– 06 (Iowa 2013) (reporting violations of law regarding health and safety of patients in an assisted living facility); Jasper, 764 N.W.2d at 766–67 (finding sufficient public policy rationale in administrative rule regarding ratio of children to daycare providers); Fitzgerald, 613 N.W.2d at 286–88 (refusing to commit or suborn perjury); Teachout, 584 N.W.2d at 300–01 (reporting of child abuse); Tullis v. Merrill, 584 N.W.2d 236, 239 (Iowa 1998) (complaining that company was not paying insurance benefits); Lara v.

2015See, e.g., Dorshkind v. Oak Park Place of Dubuque II, L.L.C., 835 N.W.2d 293 , 303– 06 (Iowa 2013) (reporting violations of law regarding health and safety of patients in an assisted living facility); Jasper, 764 N.W.2d at 766–67 (finding sufficient public policy rationale in administrative rule regarding ratio of children to daycare providers); Fitzgerald, 613 N.W.2d at 286–88 (refusing to commit or suborn perjury); Teachout, 584 N.W.2d at 300–01 (reporting of child abuse); Tullis v. Merrill, 584 N.W.2d 236, 239 (Iowa 1998) (complaining that company was not paying insurance benefits); Lara v.

2015See, e.g., Dorshkind v. Oak Park Place of Dubuque II, L.L.C., 835 N.W.2d 293 , 303– 06 (Iowa 2013) (reporting violations of law regarding health and safety of patients in an assisted living facility); Jasper, 764 N.W.2d at 766–67 (finding sufficient public policy rationale in administrative rule regarding ratio of children to daycare providers); Fitzgerald, 613 N.W.2d at 286–88 (refusing to commit or suborn perjury); Teachout, 584 N.W.2d at 300–01 (reporting of child abuse); Tullis v. Merrill, 584 N.W.2d 236, 239 (Iowa 1998) (complaining that company was not paying insurance benefits); Lara v.

2015See, e.g., Dorshkind v. Oak Park Place of Dubuque II, L.L.C., 835 N.W.2d 293 , 303– 06 (Iowa 2013) (reporting violations of law regarding health and safety of patients in an assisted living facility); Jasper, 764 N.W.2d at 766–67 (finding sufficient public policy rationale in administrative rule regarding ratio of children to daycare providers); Fitzgerald, 613 N.W.2d at 286–88 (refusing to commit or suborn perjury); Teachout, 584 N.W.2d at 300–01 (reporting of child abuse); Tullis v. Merrill, 584 N.W.2d 236, 239 (Iowa 1998) (complaining that company was not paying insurance benefits); Lara v.

2023Because we must proceed cautiously when determining whether to create a wrongful discharge claim, it is not enough for this court to rely on “generalized concepts of fairness and justice.” Harvey v. Care Initiatives, Inc., 634 N.W.2d 681, 686 (Iowa 2001).

2023Because we must proceed cautiously when determining whether to create a wrongful discharge claim, it is not enough for this court to rely on “generalized concepts of fairness and justice.” Harvey v. Care Initiatives, Inc., 634 N.W.2d 681, 686 (Iowa 2001).

2017Vaughn, 459 N.W.2d at 637–38 (Iowa 1990); see also Smidt v. Porter, 695 N.W.2d 9, 17 (Iowa 2005); Borschel, 512 N.W.2d at 567–68; Hamilton v. First Baptist Elderly Hous.

2017Vaughn, 459 N.W.2d at 637–38 (Iowa 1990); see also Smidt v. Porter, 695 N.W.2d 9, 17 (Iowa 2005); Borschel, 512 N.W.2d at 567–68; Hamilton v. First Baptist Elderly Hous.

2023Reasoning from Jasper’s statement that “[t]he tort of wrongful discharge does not impose liability for the discharge from employment, but the wrongful reasons motivating the discharge,” 764 N.W.2d at 776 , Valdez asserts individual liability against Johnson is proper here because “both the wrongful activity and wrongful motivations behind that activity (harassing behavior) were held by Johnson.”8 8Neither Defendants nor Valdez address on appeal the issue of whether a wrongful discharge claim includes constructive discharge or whether it is limited to instances of actual discharge.

2023Reasoning from Jasper’s statement that “[t]he tort of wrongful discharge does not impose liability for the discharge from employment, but the wrongful reasons motivating the discharge,” 764 N.W.2d at 776 , Valdez asserts individual liability against Johnson is proper here because “both the wrongful activity and wrongful motivations behind that activity (harassing behavior) were held by Johnson.”8 8Neither Defendants nor Valdez address on appeal the issue of whether a wrongful discharge claim includes constructive discharge or whether it is limited to instances of actual discharge.

2024“Statutes are the main sources we have relied upon when identifying public policies to support a wrongful discharge claim.” Berry, 803 N.W.2d at 110 .

2024“Statutes are the main sources we have relied upon when identifying public policies to support a wrongful discharge claim.” Berry, 803 N.W.2d at 110 .

2017But it did not . . . .” Hagen I, 964 F. Supp. 2d at 970 .

2015(Hagen I), 964 F. Supp. 2d 951, 972 (N.D.

2017Unless a public policy is “clear and apparent,” “public policy is best left to our legislative branch of government to decide as representatives of 45 the people.” Galloway v. State, 790 N.W.2d 252, 259 (Iowa 2010) (Cady, J., dissenting).

2017Unless a public policy is “clear and apparent,” “public policy is best left to our legislative branch of government to decide as representatives of 45 the people.” Galloway v. State, 790 N.W.2d 252, 259 (Iowa 2010) (Cady, J., dissenting).

2015See, e.g., Dorshkind v. Oak Park Place of Dubuque II, L.L.C., 835 N.W.2d 293 , 303– 06 (Iowa 2013) (reporting violations of law regarding health and safety of patients in an assisted living facility); Jasper, 764 N.W.2d at 766–67 (finding sufficient public policy rationale in administrative rule regarding ratio of children to daycare providers); Fitzgerald, 613 N.W.2d at 286–88 (refusing to commit or suborn perjury); Teachout, 584 N.W.2d at 300–01 (reporting of child abuse); Tullis v. Merrill, 584 N.W.2d 236, 239 (Iowa 1998) (complaining that company was not paying insurance benefits); Lara v.

2015See, e.g., Dorshkind v. Oak Park Place of Dubuque II, L.L.C., 835 N.W.2d 293 , 303– 06 (Iowa 2013) (reporting violations of law regarding health and safety of patients in an assisted living facility); Jasper, 764 N.W.2d at 766–67 (finding sufficient public policy rationale in administrative rule regarding ratio of children to daycare providers); Fitzgerald, 613 N.W.2d at 286–88 (refusing to commit or suborn perjury); Teachout, 584 N.W.2d at 300–01 (reporting of child abuse); Tullis v. Merrill, 584 N.W.2d 236, 239 (Iowa 1998) (complaining that company was not paying insurance benefits); Lara v.

2015See, e.g., Dorshkind v. Oak Park Place of Dubuque II, L.L.C., 835 N.W.2d 293 , 303– 06 (Iowa 2013) (reporting violations of law regarding health and safety of patients in an assisted living facility); Jasper, 764 N.W.2d at 766–67 (finding sufficient public policy rationale in administrative rule regarding ratio of children to daycare providers); Fitzgerald, 613 N.W.2d at 286–88 (refusing to commit or suborn perjury); Teachout, 584 N.W.2d at 300–01 (reporting of child abuse); Tullis v. Merrill, 584 N.W.2d 236, 239 (Iowa 1998) (complaining that company was not paying insurance benefits); Lara v.

2015See, e.g., Dorshkind v. Oak Park Place of Dubuque II, L.L.C., 835 N.W.2d 293 , 303– 06 (Iowa 2013) (reporting violations of law regarding health and safety of patients in an assisted living facility); Jasper, 764 N.W.2d at 766–67 (finding sufficient public policy rationale in administrative rule regarding ratio of children to daycare providers); Fitzgerald, 613 N.W.2d at 286–88 (refusing to commit or suborn perjury); Teachout, 584 N.W.2d at 300–01 (reporting of child abuse); Tullis v. Merrill, 584 N.W.2d 236, 239 (Iowa 1998) (complaining that company was not paying insurance benefits); Lara v.

2010In Kohrt v. MidAmerican Energy Co., 364 F.3d 894, 902 (8th Cir.2004), the court held the Iowa Supreme Court would recognize a wrongful discharge claim where an employee complains internally about safety issues to the employer.

2010In Kohrt v. MidAmerican Energy Co., 364 F.3d 894, 902 (8th Cir. 2004), the court held the Iowa Supreme Court would recognize a wrongful discharge claim where an employee complains internally about safety issues to the employer.

2017Vaughn, 459 N.W.2d at 637–38 (Iowa 1990); see also Smidt v. Porter, 695 N.W.2d 9, 17 (Iowa 2005); Borschel, 512 N.W.2d at 567–68; Hamilton v. First Baptist Elderly Hous.

2017Vaughn, 459 N.W.2d at 637–38 (Iowa 1990); see also Smidt v. Porter, 695 N.W.2d 9, 17 (Iowa 2005); Borschel, 512 N.W.2d at 567–68; Hamilton v. First Baptist Elderly Hous.

2015See, e.g., Dorshkind v. Oak Park Place of Dubuque II, L.L.C., 835 N.W.2d 293 , 303– 06 (Iowa 2013) (reporting violations of law regarding health and safety of patients in an assisted living facility); Jasper, 764 N.W.2d at 766–67 (finding sufficient public policy rationale in administrative rule regarding ratio of children to daycare providers); Fitzgerald, 613 N.W.2d at 286–88 (refusing to commit or suborn perjury); Teachout, 584 N.W.2d at 300–01 (reporting of child abuse); Tullis v. Merrill, 584 N.W.2d 236, 239 (Iowa 1998) (complaining that company was not paying insurance benefits); Lara v.

2015See, e.g., Dorshkind v. Oak Park Place of Dubuque II, L.L.C., 835 N.W.2d 293 , 303– 06 (Iowa 2013) (reporting violations of law regarding health and safety of patients in an assisted living facility); Jasper, 764 N.W.2d at 766–67 (finding sufficient public policy rationale in administrative rule regarding ratio of children to daycare providers); Fitzgerald, 613 N.W.2d at 286–88 (refusing to commit or suborn perjury); Teachout, 584 N.W.2d at 300–01 (reporting of child abuse); Tullis v. Merrill, 584 N.W.2d 236, 239 (Iowa 1998) (complaining that company was not paying insurance benefits); Lara v.

2018Courts are reluctant to recognize a parallel common-law action that might undermine the civil-service system’s administrative 2In Godfrey v. State, a majority of our court concluded the absence of punitive damages under the Iowa Civil Rights Act (ICRA) did not make its statutory remedies inadequate. 898 N.W.2d 844, 881 (Iowa 2017) (Cady, C.J., concurring in part and dissenting in part) (“While not providing punitive damages, [the ICRA] provides full compensation and attorney fees.

2017Sanford v. Meadow Gold Dairies, Inc., 534 N.W.2d 410, 414 (Iowa 1995).

2017The court, assuming the viability of Sanford’s wrongful-discharge claim, reasoned: “Sanford’s retaliatory discharge claim rests on our holdings that public policy is violated when an employee, even an employee at-will, is discharged as a result of seeking workers’ compensation benefits,” id. at 412 , and: “[T]here is really no argument concerning the terms or effect of the union contract.

2011Though difficult to define, we have stated the concept of public policy “generally captures the communal conscience and common sense of our state in matters of public health, safety, morals, and general welfare.” Id. at 761 ; accord Thompto, 871 F.Supp. at 1117 (recognizing public policy consists of matters that are fundamental to citizens’ social rights, duties, and responsibilities).

2004Davis v. Horton, 661 N.W.2d 533, 535 (Iowa 2003) (citing Fitzgerald, 613 N.W.2d at 282 n. 2); accord Teachout v. Forest City Cmty. Sch, Dist., 584 N.W.2d 296, 299 (Iowa 1998) (identifying the elements of a wrongful-discharge claim rooted in a violation of public policy as (1) engagement in a protected activity; (2) discharge; and (3) a causal connection between the conduct and the discharge).

1992See id.