disability discrimination claim in Iowa

2026“To prevail on a disability discrimination claim under the ICRA, [the plaintiff] must initially prove a prima facie case by showing: (1) he has a disability, (2) he is qualified to perform the essential functions of [the position], and (3) the circumstances of his termination raise an inference of illegal discrimination.” Id. (quoting Goodpaster v. Schwan’s Home Serv., Inc., 849 N.W.2d 1, 6 (Iowa 2014)).

2017In short, the disabled employee’s ability to perform the job’s essential functions is a required element in a disability discrimination claim, i.e., “qualified employee,” and Iowa courts evaluate the interrelationship of (1) the extent of the employee’s disability and (2) the essential job functions.5 See id. 5 On appeal, Remmick contends there is a fact question as to whether she is a qualified employee because the disability leading to her inability to perform her job was caused by her co-workers’ treatment when she returned from her first leave and by Carlson requiring Remmick to explain he

2014See Schlitzer v. Univ. of Iowa Hosp. & Clinics, 641 N.W.2d 525, 530 (Iowa 2002).

2014See Schlitzer v. Univ. of Iowa Hosp. & Clinics, 641 N.W.2d 525, 530 (Iowa 2002).

2014See Henkel, 471 N.W.2d at 810 . 20 B.

2014See Henkel, 471 N.W.2d at 810 . 20 B.

2009See Bd. of Supervisors v. Iowa Civil Rights Comm’n, 584 N.W.2d 252, 256 (Iowa 1998) (“In deciding gender discrimination disputes, we adhere to the Title VII analytical framework. ...”); Fuller v. Iowa Dep’t of Human Servs., 576 N.W.2d 324, 329 (Iowa 1998) (“In considering a disability discrimination claim brought under Iowa Code chapter 216, we look to the ADA and cases interpreting its language.”).

2009See Bd. of Supervisors v. 8 Iowa Civil Rights Comm’n, 584 N.W.2d 252, 256 (Iowa 1998) (“In deciding gender discrimination disputes, we adhere to the Title VII analytical framework . . . .”); Fuller v. Iowa Dep’t of Human Servs., 576 N.W.2d 324, 329 (Iowa 1998) (“In considering a disability discrimination claim brought under Iowa Code chapter 216, we look to the ADA and cases interpreting its language.”).

2009See Bd. of Supervisors v. Iowa Civil Rights Comm’n, 584 N.W.2d 252, 256 (Iowa 1998) (“In deciding gender discrimination disputes, we adhere to the Title VII analytical framework. ...”); Fuller v. Iowa Dep’t of Human Servs., 576 N.W.2d 324, 329 (Iowa 1998) (“In considering a disability discrimination claim brought under Iowa Code chapter 216, we look to the ADA and cases interpreting its language.”).

2009See Bd. of Supervisors v. 8 Iowa Civil Rights Comm’n, 584 N.W.2d 252, 256 (Iowa 1998) (“In deciding gender discrimination disputes, we adhere to the Title VII analytical framework . . . .”); Fuller v. Iowa Dep’t of Human Servs., 576 N.W.2d 324, 329 (Iowa 1998) (“In considering a disability discrimination claim brought under Iowa Code chapter 216, we look to the ADA and cases interpreting its language.”).

2009However, we must be mindful not to substitute “the language of the federal statutes for the clear words of the Iowa Civil Rights Act.” Hulme v. Barrett, 449 N.W.2d 629, 631 (Iowa 1989).

2009However, we must be mindful not to substitute “the language of the federal statutes for the clear words of the Iowa Civil Rights Act.” Hulme v. Barrett, 449 N.W.2d 629, 631 (Iowa 1989).

2002(Emphasis added.) Our review of a disability discrimination claim is at law, Boelman v. Manson State Bank, 522 N.W.2d 73, 76 (Iowa 1994), and we are bound by the court’s findings of fact if supported by substantial evidence.

1995Boelman v. Manson State Bank, 522 N.W.2d 73, 76 (Iowa 1994).

2026“To prevail on a disability discrimination claim under the ICRA, [the plaintiff] must initially prove a prima facie case by showing: (1) he has a disability, (2) he is qualified to perform the essential functions of [the position], and (3) the circumstances of his termination raise an inference of illegal discrimination.” Id. (quoting Goodpaster v. Schwan’s Home Serv., Inc., 849 N.W.2d 1, 6 (Iowa 2014)).

2017Stores, 661 N.W.2d at 521 (holding an employer’s failure to make 5 Once an employee has proved the elements of a disability-discrimination claim, the employer may rely on an affirmative defense like undue hardship to insulate it from liability.

2026See also Hoback v. City of Chattanooga, 550 F. App’x 257, 260 (6th Cir. 2013) (affirming a jury verdict in favor of a police officer on a disability-discrimination claim where the officer had PTSD and had failed a psychological fitness-for-duty test before being terminated but two subsequent psychological evaluations concluded that the plaintiff could perform the duties of an officer).

2026Merely believing that someone with PTSD is unfit to be a cop would not be illegal unless all the elements of a disability-discrimination claim were proven. 28 Hunter relies on the following statement that we made in Palmer College of Chiropractic v. Davenport Civil Rights Commission, 850 N.W.2d 326, 333 (Iowa 2014), reading the federal law that often guides our interpretation of the ICRA: “Both the ADA and the Rehabilitation Act specifically prohibit discrimination against those with disabilities based not just on ‘affirmative animus,’ but also any discrimination based on thoughtlessness, apat

2026The point we were making was that a disability-discrimination claim doesn’t require the defendant to be overtly hostile toward people with the plaintiff’s disability; the defendant could be aware of the disability and violate the law out of “thoughtlessness, apathy, or stereotype.” Id.

2025See Withers v. Johnson, 763 F.3d 998, 1003 (8th Cir. 2014).

2021Instruction No. 17 for the disability discrimination claim required Rumsey to prove as element four: At the time of his termination, Plaintiff could have performed the “essential functions” of his job, with or without “reasonable accommodations.” Instruction No. 19 for the failure-to-accommodate claim required Rumsey to prove as element four: The Plaintiff could have performed the essential functions of his job at the time of his termination if the Plaintiff had been provided with sit down work and/or a sign language interpreter. 1See Neal v. Annett Holdings, Inc., 814 N.W.2d 512, 519 (Iowa 20

2018See, e.g., Cordoba v. Dillard’s, Inc., 419 F.3d 1169, 1183 (11th Cir. 2005) (“[The store manager] could not have fired [the employee] ‘because of’ a disability that she knew nothing about.”); Taylor, 93 F.3d at 163 (“To 25 prove discrimination, an employee must show that the employer knew of such employee’s substantial physical or mental limitation.”); Hedberg, 47 F.3d at 933 n.5 (“[W]here there is no genuine issue that an employer did not know of an employee’s disability when it decided to fire him, the employee cannot make out a case of discriminatory discharge.”); Streeter v. Premier Servs.

2018See, e.g. , Cordoba v. Dillard's, Inc. , 419 F.3d 1169 , 1183 (11th Cir. 2005) ("[The store manager] could not have fired [the employee] 'because of' a disability that she knew nothing about."); Taylor , 93 F.3d at 163 ("To prove discrimination, an employee must show that the employer knew of such employee's substantial physical or mental limitation."); Hedberg , 47 F.3d at 933 n.5 ("[W]here there is no genuine issue that an employer did not know of an employee's disability when it decided to fire him, the employee cannot make out a case of discriminatory discharge."); Streeter v. Premier Serv

2018See, e.g., Cordoba v. Dillard’s, Inc., 419 F.3d 1169, 1183 (11th Cir. 2005) (“[The store manager] could not have fired [the employee] ‘because of’ a disability that she knew nothing about.”); Taylor, 93 F.3d at 163 (“To 25 prove discrimination, an employee must show that the employer knew of such employee’s substantial physical or mental limitation.”); Hedberg, 47 F.3d at 933 n.5 (“[W]here there is no genuine issue that an employer did not know of an employee’s disability when it decided to fire him, the employee cannot make out a case of discriminatory discharge.”); Streeter v. Premier Servs.

2018See, e.g. , Cordoba v. Dillard's, Inc. , 419 F.3d 1169 , 1183 (11th Cir. 2005) ("[The store manager] could not have fired [the employee] 'because of' a disability that she knew nothing about."); Taylor , 93 F.3d at 163 ("To prove discrimination, an employee must show that the employer knew of such employee's substantial physical or mental limitation."); Hedberg , 47 F.3d at 933 n.5 ("[W]here there is no genuine issue that an employer did not know of an employee's disability when it decided to fire him, the employee cannot make out a case of discriminatory discharge."); Streeter v. Premier Serv

2018See, e.g., Cordoba v. Dillard’s, Inc., 419 F.3d 1169, 1183 (11th Cir. 2005) (“[The store manager] could not have fired [the employee] ‘because of’ a disability that she knew nothing about.”); Taylor, 93 F.3d at 163 (“To 25 prove discrimination, an employee must show that the employer knew of such employee’s substantial physical or mental limitation.”); Hedberg, 47 F.3d at 933 n.5 (“[W]here there is no genuine issue that an employer did not know of an employee’s disability when it decided to fire him, the employee cannot make out a case of discriminatory discharge.”); Streeter v. Premier Servs.

2018See, e.g. , Cordoba v. Dillard's, Inc. , 419 F.3d 1169 , 1183 (11th Cir. 2005) ("[The store manager] could not have fired [the employee] 'because of' a disability that she knew nothing about."); Taylor , 93 F.3d at 163 ("To prove discrimination, an employee must show that the employer knew of such employee's substantial physical or mental limitation."); Hedberg , 47 F.3d at 933 n.5 ("[W]here there is no genuine issue that an employer did not know of an employee's disability when it decided to fire him, the employee cannot make out a case of discriminatory discharge."); Streeter v. Premier Serv

2017Cf. Lamb v. Qualex, Inc., 33 F. App’x 49, 59 (4th Cir. 2002) (noting that once the plaintiff has established the elements of a discrimination case, the defendant may present evidence of an affirmative defense (specifically citing the affirmative defense of undue hardship)); Willis v. Conopco, Inc., 108 F.3d 282, 286 (11th Cir. 1997) (distinguishing an employee’s burden of establishing a reasonable accommodation exists as part of its burden of proof with the employer’s burden of pleading and proving the affirmative defense of undue hardship). 15 a reasonable accommodation for an otherwise quali

2017Cf. Lamb v. Qualex, Inc., 33 F. App’x 49, 59 (4th Cir. 2002) (noting that once the plaintiff has established the elements of a discrimination case, the defendant may present evidence of an affirmative defense (specifically citing the affirmative defense of undue hardship)); Willis v. Conopco, Inc., 108 F.3d 282, 286 (11th Cir. 1997) (distinguishing an employee’s burden of establishing a reasonable accommodation exists as part of its burden of proof with the employer’s burden of pleading and proving the affirmative defense of undue hardship). 15 a reasonable accommodation for an otherwise quali

2017Cf. Lamb v. Qualex, Inc., 33 F. App’x 49, 59 (4th Cir. 2002) (noting that once the plaintiff has established the elements of a discrimination case, the defendant may present evidence of an affirmative defense (specifically citing the affirmative defense of undue hardship)); Willis v. Conopco, Inc., 108 F.3d 282, 286 (11th Cir. 1997) (distinguishing an employee’s burden of establishing a reasonable accommodation exists as part of its burden of proof with the employer’s burden of pleading and proving the affirmative defense of undue hardship). 15 a reasonable accommodation for an otherwise quali

2015See Vincent v. Four M Paper Corp., 589 N.W.2d 55, 61 (Iowa 1999) (including a permanency analysis as an important factor in a disability discrimination claim under the statute).

1997Falezynski v. Amoco Oil Co., 533 N.W.2d 226, 234-35 (Iowa 1995).

1994Compare Hollinrake v. Monroe County, 433 N.W.2d 696 (Iowa 1988) (a disability discrimination claim based on the substance of a rule enacted by the Iowa Law Enforcement Academy must be challenged under the judicial review procedures of chapter 17A; the ICRC did not have authority to hear the challenge as a civil rights action) with Jew v. University of Iowa, 398 N.W.2d 861 (Iowa 1987) (sexual harassment claim by associate professor may be pursued under chapter 601A; chapter 17A did not provide the exclusive means to challenge the University's action).

1994Landals v. George A. Rolfes Co., 454 N.W.2d 891, 892 (Iowa 1990).