hostile work environment claim in Iowa

2025To establish a hostile work environment claim under the ICRA, “the plaintiff must show: (1) he or she belongs to a protected group; (2) he or she was subjected to unwelcome harassment; (3) the harassment was 13 based on a protected characteristic; and (4) the harassment affected a term, condition, or privilege of employment.” Boyle v. Alum-Line, Inc., 710 N.W.2d 741, 746 (Iowa 2006) (citation omitted).

2025“To establish a hostile-work-environment claim under the ICRA,” a plaintiff must show (1) she “belongs to a protected group,” (2) she “was subjected to unwelcome harassment,” (3) “the harassment was based on a protected characteristic,” and (4) “the harassment affected a term, condition, or privilege of employment.” Haskenhoff v. Homeland Energy Sols., LLC, 897 N.W.2d 553, 571 (Iowa 2017) (quoting Boyle v. Alum-Line, Inc., 710 N.W.2d 741, 746 (Iowa 2006)).

2017We first recognized a hostile-work- environment claim for sex discrimination in Lynch v. City of Des Moines, 454 N.W.2d 827, 833 (Iowa 1990), relying on Chauffeurs, Teamsters & Helpers, Local Union No. 238 v. Iowa Civil Rights Commission, 394 N.W.2d 375, 378 (Iowa 1986).

2017We first recognized a hostile-work- environment claim for sex discrimination in Lynch v. City of Des Moines, 454 N.W.2d 827, 833 (Iowa 1990), relying on Chauffeurs, Teamsters & Helpers, Local Union No. 238 v. Iowa Civil Rights Commission, 394 N.W.2d 375, 378 (Iowa 1986).

2019To establish a hostile-work-environment claim under the ICRA, a plaintiff must show: “(1) he or she belongs to a protected group; (2) he or she was subjected to unwelcome harassment; (3) the harassment was based on a protected characteristic; and (4) the harassment affected a term, condition, or privilege of employment.” Boyle v. Alum-Line, Inc., 710 N.W.2d 741, 746 (Iowa 2006) (quoting Farmland Foods, Inc. v. Dubuque Human Rights Comm’n, 672 N.W.2d 733, 744 (Iowa 2003)). 6 An employer may be entitled to the Faragher-Ellerth affirmative defense to claims of vicarious liability for harassment b

2017Iowa adopted the vicarious liability standard of Ellerth and Faragher in Farmland Foods, a hostile-work-environment claim under the ICRA. 672 N.W.2d at 744 .

2025“To establish a hostile-work-environment claim under the ICRA,” a plaintiff must show (1) she “belongs to a protected group,” (2) she “was subjected to unwelcome harassment,” (3) “the harassment was based on a protected characteristic,” and (4) “the harassment affected a term, condition, or privilege of employment.” Haskenhoff v. Homeland Energy Sols., LLC, 897 N.W.2d 553, 571 (Iowa 2017) (quoting Boyle v. Alum-Line, Inc., 710 N.W.2d 741, 746 (Iowa 2006)).

2024Haskenhoff v. Homeland Energy Sols., LLC, 897 N.W.2d 553, 571 (Iowa 2017).

2017Chauffeurs, in turn, delineated the elements of a racial hostile-work-environment harassment claim, relying on Henson v. City of Dundee, 682 F.2d 897, 909 (11th Cir. 1982), a Federal Title VII case, for the appropriate framework under the ICRA.

2017Chauffeurs, in turn, delineated the elements of a racial hostile-work-environment harassment claim, relying on Henson v. City of Dundee, 682 F.2d 897, 909 (11th Cir. 1982), a Federal Title VII case, for the appropriate framework under the ICRA.

2017We first recognized a hostile-work- environment claim for sex discrimination in Lynch v. City of Des Moines, 454 N.W.2d 827, 833 (Iowa 1990), relying on Chauffeurs, Teamsters & Helpers, Local Union No. 238 v. Iowa Civil Rights Commission, 394 N.W.2d 375, 378 (Iowa 1986).

2017We first recognized a hostile-work- environment claim for sex discrimination in Lynch v. City of Des Moines, 454 N.W.2d 827, 833 (Iowa 1990), relying on Chauffeurs, Teamsters & Helpers, Local Union No. 238 v. Iowa Civil Rights Commission, 394 N.W.2d 375, 378 (Iowa 1986).

2003See Harris, 510 U.S. at 21 , 114 S.Ct. at 370 , 126 L.Ed.2d at 302 (“Conduct that is not severe or pervasive enough to create an objectively hostile or abusive work environment — an environment that a reasonable person would find hostile or abusive — is beyond Title VII’s purview.”).

2003See Harris, 510 U.S. at 21 , 114 S.Ct. at 370 , 126 L.Ed.2d at 302 (“Conduct that is not severe or pervasive enough to create an objectively hostile or abusive work environment — an environment that a reasonable person would find hostile or abusive — is beyond Title VII’s purview.”).

2015The Court explained that a hostile work environment claim “cannot be said to occur on any particular day,” but “occurs over a series of days or perhaps years” and is “based on the cumulative effect of individual acts.” Id. at 115, 122 S. Ct. at 2073 , 153 L.

2015The Court explained that a hostile work environment claim “cannot be said to occur on any particular day,” but “occurs over a series of days or perhaps years” and is “based on the cumulative effect of individual acts.” Id. at 115, 122 S. Ct. at 2073 , 153 L.

2025See Lamasters v. State, 821 N.W.2d 856, 864 (Iowa 2012) (“If the court’s ruling indicates that the court considered the issue and necessarily ruled on it, even if the reasoning is ‘incomplete or sparse,’ the issue has been preserved.” (citation omitted)).

2025Iowa 2000)); see also White v. State, 5 N.W.3d 315 , 324 (Iowa 2024) (reciting similar elements as those required “to establish a hostile-work-environment claim under the ICRA”). 10 decisions interpreting the FHA,” State v. Keding, 553 N.W.2d 305, 307 (Iowa 1996), and our sister states’ caselaw interpreting substantially similar statutory provisions, Pippen v. State, 854 N.W.2d 1, 30 (Iowa 2014).

2025Iowa 2000)); see also White v. State, 5 N.W.3d 315 , 324 (Iowa 2024) (reciting similar elements as those required “to establish a hostile-work-environment claim under the ICRA”). 10 decisions interpreting the FHA,” State v. Keding, 553 N.W.2d 305, 307 (Iowa 1996), and our sister states’ caselaw interpreting substantially similar statutory provisions, Pippen v. State, 854 N.W.2d 1, 30 (Iowa 2014).

2025In doing so, we remain faithful to our obligation to construe the ICRA “broadly to effectuate its purposes.”9 Pippen, 854 N.W.2d at 28 (quoting Iowa Code § 216.18 (1)); accord Hawkins v. Grinnell Reg’l Med.

2024Cir. 2023) (finding that the “seven comments [the plaintiff] identified were spread out over a span of over three-and-a-half years,” and the “relative infrequency” of the “remarks—reflecting one or two statements in a given six-month period—indicate[d] that his actions were not severe or pervasive harassment”). “[L]arge temporal gaps between allegations undermine a hostile- work-environment claim” and “suggest occasional problems, not pervasive ones.” McIver v. Bridgestone Ams., Inc., 42 F.4th 398, 408 (4th Cir. 2022).

2024Univ., 388 F.3d 559, 567 (7th Cir. 2004) (“While certainly relevant to the determination of a hostile work environment claim, when harassment is ‘directed at someone other than the plaintiff, the “impact of [such] ‘second-hand harassment’ is obviously not as great as the impact of harassment directed at the plaintiff.” ’ ” (alteration in original) (quoting McPhaul v. Bd. of Comm’rs, 226 F.3d 558 , 567 (7th Cir. 2000), overruled in part by Hill v. Tangherlini, 724 F.3d 965 (7th Cir. 2013))).

2019See Fenceroy, 908 N.W.2d at 241–42. “[V]icarious liability does not replace the direct negligence theory of employer liability, but rather supplements the theory with an additional agency-based standard.” Id. at 242.

2019See Fenceroy, 908 N.W.2d at 241–42. “[V]icarious liability does not replace the direct negligence theory of employer liability, but rather supplements the theory with an additional agency-based standard.” Id. at 242.

2015See Leichliter v. The Des Moines Register, 617 F. Supp. 2d 818, 827 (S.D.

2006See Farmland Foods, Inc. v. Dubuque Human Rights Comm’n, 672 N.W.2d 733, 744 (Iowa 2003) (noting that an employer’s failure to take proper remedial action in response to harassment by a nonsupervisory employee is an essential element of a hostile-work-environment claim under the civil rights acts); see also Taylor v. Jones, 653 F.2d 1193, 1199 (8th Cir.1981) (“[E]mployer toleration of a discriminatory atmosphere alone gives rise to a cause of action by the [employee].”).