at-will doctrine in Iowa

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 Dorshkind, 835 N.W.2d at 303 (noting that “[w]e cautiously identify policies to support an action for wrongful discharge” and avoid reliance on “generalized concepts of fairness and justice” (quoting Fitz- gerald, 613 N.W.2d at 283 )); see also Lloyd v. Drake Univ., 686 N.W.2d 225 , 230–31 (Iowa 2004) (rejecting the claim of a security guard who was fired after forcibly restraining a student suspected of assault because a public policy against crime “is far too generalized to support an argument for an exception to the at-will doctrine”).

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 Dorshkind, 835 N.W.2d at 303 (noting that “[w]e cautiously identify policies to support an action for wrongful discharge” and avoid reliance on “generalized concepts of fairness and justice” (quoting Fitz- gerald, 613 N.W.2d at 283 )); see also Lloyd v. Drake Univ., 686 N.W.2d 225 , 230–31 (Iowa 2004) (rejecting the claim of a security guard who was fired after forcibly restraining a student suspected of assault because a public policy against crime “is far too generalized to support an argument for an exception to the at-will doctrine”).

2023See Dorshkind, 835 N.W.2d at 303 (noting that “[w]e cautiously identify policies to support an action for wrongful discharge” and avoid reliance on “generalized concepts of fairness and justice” (quoting Fitz- gerald, 613 N.W.2d at 283 )); see also Lloyd v. Drake Univ., 686 N.W.2d 225 , 230–31 (Iowa 2004) (rejecting the claim of a security guard who was fired after forcibly restraining a student suspected of assault because a public policy against crime “is far too generalized to support an argument for an exception to the at-will doctrine”).

2023See Dorshkind, 835 N.W.2d at 303 (noting that “[w]e cautiously identify policies to support an action for wrongful discharge” and avoid reliance on “generalized concepts of fairness and justice” (quoting Fitz- gerald, 613 N.W.2d at 283 )); see also Lloyd v. Drake Univ., 686 N.W.2d 225 , 230–31 (Iowa 2004) (rejecting the claim of a security guard who was fired after forcibly restraining a student suspected of assault because a public policy against crime “is far too generalized to support an argument for an exception to the at-will doctrine”).

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

2019See Springer v. Weeks & Leo Co., 429 N.W.2d 558 (Iowa 1988) (en banc).

1995We have carved out only two narrow deviations: tort liability when a discharge is in clear violation of a “well-recognized and defined public policy of the State,” Springer v. Weeks & Leo Co., 429 N.W.2d 558, 560 (Iowa 1988), and employee handbooks that meet the requirements for a unilateral contract, French v. Foods, Inc., 495 N.W.2d 768, 769-71 (Iowa 1993).

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).

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

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

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

2000Burnham v. Karl & Gelb, P.C., 252 Conn. 153 , 745 A.2d 178, 182 (2000) (public policy exception is narrow and courts should not lightly intervene to impair the exercise of managerial discretion).

2000Burnham v. Karl & Gelb, P.C., 252 Conn. 153 , 745 A.2d 178, 182 (2000) (public policy exception is narrow and courts should not lightly intervene to impair the exercise of managerial discretion).

2000Co., 148 N.Y. 117 , 42 N.E. 416, 417 (1895), and quickly became the prevailing rule throughout the country. 1 The United States Supreme Court gave the doctrine a boost in 1908 in Adair v. United States, when it found a federal law making it a crime to discharge an employee for being a member of a union violated due process guarantees of freedom of contract.

2000Co., 148 N.Y. 117 , 42 N.E. 416, 417 (1895), and quickly became the prevailing rule throughout the country. 1 The United States Supreme Court gave the doctrine a boost in 1908 in Adair v. United States, when it found a federal law making it a crime to discharge an employee for being a member of a union violated due process guarantees of freedom of contract.

1995We have carved out only two narrow deviations: tort liability when a discharge is in clear violation of a “well-recognized and defined public policy of the State,” Springer v. Weeks & Leo Co., 429 N.W.2d 558, 560 (Iowa 1988), and employee handbooks that meet the requirements for a unilateral contract, French v. Foods, Inc., 495 N.W.2d 768, 769-71 (Iowa 1993).

1994Porter v. Pioneer Hi-Bred Int’l, Inc., 497 N.W.2d 870, 871 (Iowa 1993); Fogel v. Trustees of Iowa College, 446 N.W.2d 451, 456-57 (Iowa 1989).

1994Porter v. Pioneer Hi-Bred Int’l, Inc., 497 N.W.2d 870, 871 (Iowa 1993); Fogel v. Trustees of Iowa College, 446 N.W.2d 451, 456-57 (Iowa 1989).

1989Benishek apparently concedes that she is an “at will” employee, see Abrisz v. Pulley Freight Lines, Inc., 270 N.W.2d 454, 455 (Iowa 1978), however, she argues that one of two exceptions to the at-will doctrine apply to the facts of this case, The first alleged exception is based upon Benishek’s claim that “a fact finder could reasonably find that there was in existence an implied employment agreement for life or until retirement,” despite the fact that she admitted she had neither a written nor oral contract of employment with defendants.