employment-at-will doctrine in Iowa

2023In Springer v. Weeks & Leo Co., Inc., this court adopted a limited exception to the employment-at-will doctrine by creating an implied cause of action for wrongful discharge where an employer terminates an employee in violation of a clearly established public policy. 429 N.W.2d 558, 559 (Iowa 1988) (en banc).

2023In Springer v. Weeks & Leo Co., Inc., this court adopted a limited exception to the employment-at-will doctrine by creating an implied cause of action for wrongful discharge where an employer terminates an employee in violation of a clearly established public policy. 429 N.W.2d 558, 559 (Iowa 1988) (en banc).

2024Nizam, Inc., 764 N.W.2d 751, 762 (Iowa 2009) (“[T]he tort of wrongful discharge should exist in Iowa only as a narrow exception to the employment-at-will doctrine.”); Lloyd v. Drake Univ., 686 N.W.2d 225, 229 (Iowa 2004) (stating we must proceed with caution before creating an implied cause of action); Davis v. Horton, 661 N.W.2d 533, 536 (Iowa 2003) (stating we must “proceed cautiously” in recognizing an implied cause of action); Fitzgerald, 613 N.W.2d at 283 (“Thus, we must proceed cautiously when asked to declare public policy to support an exception to the at-will doctrine . . . .”).

2024Under the employment-at-will doctrine, “unless a contract states otherwise, generally the employee or the employer may end the employment ‘at any time, for any reason, or no reason at all.’ ” Carver-Kimm, 992 N.W.2d at 598 (quoting Fitzgerald v. Salsbury Chem., Inc., 613 N.W.2d 275, 280 (Iowa 2000) (en banc)).

2024Nizam, Inc., 764 N.W.2d 751, 762 (Iowa 2009) (“[T]he tort of wrongful discharge should exist in Iowa only as a narrow exception to the employment-at-will doctrine.”); Lloyd v. Drake Univ., 686 N.W.2d 225, 229 (Iowa 2004) (stating we must proceed with caution before creating an implied cause of action); Davis v. Horton, 661 N.W.2d 533, 536 (Iowa 2003) (stating we must “proceed cautiously” in recognizing an implied cause of action); Fitzgerald, 613 N.W.2d at 283 (“Thus, we must proceed cautiously when asked to declare public policy to support an exception to the at-will doctrine . . . .”).

2023See id. (describing the tort as a “narrow public-policy exception”); Jasper, 764 N.W.2d at 762 (“[T]he tort of wrongful discharge should exist in Iowa only as a narrow exception to the employment-at-will doctrine.”).

2023See id. (describing the tort as a “narrow public-policy exception”); Jasper, 764 N.W.2d at 762 (“[T]he tort of wrongful discharge should exist in Iowa only as a narrow exception to the employment-at-will doctrine.”).

2023See id. (describing the tort as a “narrow public-policy exception”); Jasper, 764 N.W.2d at 762 (“[T]he tort of wrongful discharge should exist in Iowa only as a narrow exception to the employment-at-will doctrine.”).

1998E.g., Anderson, 540 N.W.2d at 282 ; Fogel v. Trustees of Iowa College, 446 N.W.2d 451, 455 (Iowa 1989).

1995Fogel v. Trustees of Iowa College, 446 N.W.2d 451, 455 (Iowa 1989).

2024Harvey 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).

2024Nizam, Inc., 764 N.W.2d 751, 762 (Iowa 2009) (“[T]he tort of wrongful discharge should exist in Iowa only as a narrow exception to the employment-at-will doctrine.”); Lloyd v. Drake Univ., 686 N.W.2d 225, 229 (Iowa 2004) (stating we must proceed with caution before creating an implied cause of action); Davis v. Horton, 661 N.W.2d 533, 536 (Iowa 2003) (stating we must “proceed cautiously” in recognizing an implied cause of action); Fitzgerald, 613 N.W.2d at 283 (“Thus, we must proceed cautiously when asked to declare public policy to support an exception to the at-will doctrine . . . .”).

2023Nizam, Inc., 764 N.W.2d 751, 762 (Iowa 2009) (“[T]he tort of wrongful discharge should exist in Iowa only as a narrow exception to the employment-at-will doctrine.”); Lloyd v. Drake Univ., 686 N.W.2d 225, 229 (Iowa 2004) (stating we must proceed with caution before creating an implied cause of action); Davis v. Horton, 661 N.W.2d 533, 536 (Iowa 2003) (stating we must “proceed cautiously”); Fitzgerald, 613 N.W.2d at 283 (“Thus, we must proceed cautiously when asked to declare public policy to support an exception to the at-will doctrine.”); Phipps, 558 N.W.2d at 202 (stating the tort is a “narr

2024Nizam, Inc., 764 N.W.2d 751, 762 (Iowa 2009) (“[T]he tort of wrongful discharge should exist in Iowa only as a narrow exception to the employment-at-will doctrine.”); Lloyd v. Drake Univ., 686 N.W.2d 225, 229 (Iowa 2004) (stating we must proceed with caution before creating an implied cause of action); Davis v. Horton, 661 N.W.2d 533, 536 (Iowa 2003) (stating we must “proceed cautiously” in recognizing an implied cause of action); Fitzgerald, 613 N.W.2d at 283 (“Thus, we must proceed cautiously when asked to declare public policy to support an exception to the at-will doctrine . . . .”).

2023Nizam, Inc., 764 N.W.2d 751, 762 (Iowa 2009) (“[T]he tort of wrongful discharge should exist in Iowa only as a narrow exception to the employment-at-will doctrine.”); Lloyd v. Drake Univ., 686 N.W.2d 225, 229 (Iowa 2004) (stating we must proceed with caution before creating an implied cause of action); Davis v. Horton, 661 N.W.2d 533, 536 (Iowa 2003) (stating we must “proceed cautiously”); Fitzgerald, 613 N.W.2d at 283 (“Thus, we must proceed cautiously when asked to declare public policy to support an exception to the at-will doctrine.”); Phipps, 558 N.W.2d at 202 (stating the tort is a “narr

2009See, e.g., Lara v. Thomas, 512 N.W.2d 777, 782 (Iowa 1994); Springer v. Weeks & Leo Co., 429 N.W.2d 558, 560 (Iowa 1988).

2009See, e.g., Lara v. Thomas, 512 N.W.2d 777, 782 (Iowa 1994); Springer v. Weeks & Leo Co., 429 N.W.2d 558, 560 (Iowa 1988).

2024Ass’n, 781 N.W.2d 272, 275 (Iowa 2010) (stating the tort is a “narrow exception” to the employment-at-will doctrine); Jasper v. H.

2013Id. at 277 (citing Kohrt v. MidAmerican Energy Co., 364 F.3d 894, 902 (8th Cir.2004)).

2023Nizam, Inc., 764 N.W.2d 751, 762 (Iowa 2009) (“[T]he tort of wrongful discharge should exist in Iowa only as a narrow exception to the employment-at-will doctrine.”); Lloyd v. Drake Univ., 686 N.W.2d 225, 229 (Iowa 2004) (stating we must proceed with caution before creating an implied cause of action); Davis v. Horton, 661 N.W.2d 533, 536 (Iowa 2003) (stating we must “proceed cautiously”); Fitzgerald, 613 N.W.2d at 283 (“Thus, we must proceed cautiously when asked to declare public policy to support an exception to the at-will doctrine.”); Phipps, 558 N.W.2d at 202 (stating the tort is a “narr

1998E.g., Anderson, 540 N.W.2d at 282 ; Fogel v. Trustees of Iowa College, 446 N.W.2d 451, 455 (Iowa 1989).

2023Nizam, Inc., 764 N.W.2d 751, 762 (Iowa 2009) (“[T]he tort of wrongful discharge should exist in Iowa only as a narrow exception to the employment-at-will doctrine.”); Lloyd v. Drake Univ., 686 N.W.2d 225, 229 (Iowa 2004) (stating we must proceed with caution before creating an implied cause of action); Davis v. Horton, 661 N.W.2d 533, 536 (Iowa 2003) (stating we must “proceed cautiously”); Fitzgerald, 613 N.W.2d at 283 (“Thus, we must proceed cautiously when asked to declare public policy to support an exception to the at-will doctrine.”); Phipps, 558 N.W.2d at 202 (stating the tort is a “narr

2001Id.

2009Gantt v. Sentry Ins., 1 Cal.4th 1083 , 4 Cal.Rptr.2d 874 , 824 P.2d 680, 686-87 (1992), overruled on other grounds by Green v. Ralee Eng’g Co., 19 Cal.4th 66 , 78 Cal.Rptr.2d 16 , 960 P.2d 1046 (1998); see also Rocky Mountain Hosp. & Med.

2009Gantt v. Sentry Ins., 1 Cal.4th 1083 , 4 Cal.Rptr.2d 874 , 824 P.2d 680, 686-87 (1992), overruled on other grounds by Green v. Ralee Eng’g Co., 19 Cal.4th 66 , 78 Cal.Rptr.2d 16 , 960 P.2d 1046 (1998); see also Rocky Mountain Hosp. & Med.

1998Our analysis of the argument requires that we briefly examine the employment-at-will doctrine in light of Tullis’s claim under chapter 91A and the definition of “wage.” The jury found, and the parties do not contest on appeal, that Tullis had no legitimate expectation of permanent employment with Merrill; he was an employee at will “subject to discharge at any time, for any reason, or for no reason at all.” French v. Foods, Inc., 495 N.W.2d 768, 769 (Iowa 1993).

1998Our analysis of the argument requires that we briefly examine the employment-at-will doctrine in light of Tullis’s claim under chapter 91A and the definition of “wage.” The jury found, and the parties do not contest on appeal, that Tullis had no legitimate expectation of permanent employment with Merrill; he was an employee at will “subject to discharge at any time, for any reason, or for no reason at all.” French v. Foods, Inc., 495 N.W.2d 768, 769 (Iowa 1993).

2023Nizam, Inc., 764 N.W.2d 751, 762 (Iowa 2009) (“[T]he tort of wrongful discharge should exist in Iowa only as a narrow exception to the employment-at-will doctrine.”); Lloyd v. Drake Univ., 686 N.W.2d 225, 229 (Iowa 2004) (stating we must proceed with caution before creating an implied cause of action); Davis v. Horton, 661 N.W.2d 533, 536 (Iowa 2003) (stating we must “proceed cautiously”); Fitzgerald, 613 N.W.2d at 283 (“Thus, we must proceed cautiously when asked to declare public policy to support an exception to the at-will doctrine.”); Phipps, 558 N.W.2d at 202 (stating the tort is a “narr

2018Ctr., Inc., 636 N.W.2d 74, 79 (Iowa 2001) (“The doctrine of employment-at-will, well-established in Iowa law, permits an employer or employee who is not under contract to terminate employment at any time for any lawful reason.”).

2013Id. at 277 (citing Kohrt v. MidAmerican Energy Co., 364 F.3d 894, 902 (8th Cir. 2004)).

2013Id. at 277 (citing Kohrt v. MidAmerican Energy Co., 364 F.3d 894, 902 (8th Cir.2004)).

1999In holding that a negligent misrepresentation claim was not viable in an *50 employment-at-will situation, we held that the parties “were dealing at arm’s length” and the employment relationship “was ‘adversarial’ in nature, not advisory.” Fry v. Mount, 554 N.W.2d 263, 266 (Iowa 1996).

1996Jur.2d Wrongful Discharge § 182 (1992); see Johnson v. Delchamps, Inc., 897 F.2d 808, 810-11 (5th Cir.1990) (under Louisiana law, employer cannot be held liable in tort for discharging at-will employee based on polygraph results, even if examination was negligently conducted); Demars v. General Dynamics Corp., 779 F.2d 95, 100-01 (1st Cir. 1985) (under Massachusetts law, an employer can “discharge an employee negligently and in bad faith”); Shaver v. F.W.

1996Jur.2d Wrongful Discharge § 182 (1992); see Johnson v. Delchamps, Inc., 897 F.2d 808, 810-11 (5th Cir.1990) (under Louisiana law, employer cannot be held liable in tort for discharging at-will employee based on polygraph results, even if examination was negligently conducted); Demars v. General Dynamics Corp., 779 F.2d 95, 100-01 (1st Cir. 1985) (under Massachusetts law, an employer can “discharge an employee negligently and in bad faith”); Shaver v. F.W.

1996Porter v. Pioneer Hi-Bred Int’l, Inc., 497 N.W.2d 870, 871 (Iowa 1993); French, 495 N.W.2d at 771 ; Grahek v. Voluntary Hosp.