McDonnell Douglas burden-shifting framework in Iowa

2025During the trial, the parties litigated the retaliation claim under the traditional McDonnell Douglas burden-shifting framework, see McDonnell Douglas Corp v. Green, 411 U.S. 792 (Iowa 1973), and they renew that approach on appeal.15 14 Both the ICRA and FHA state that “[i]t shall be unlawful to coerce, intimidate, threaten, or interfere with any person in the exercise or enjoyment of . . . any right granted or protected by” the housing provisions of the respective acts.

2020Against that backdrop, both parties and the district court analyzed the question under the McDonnell Douglas burden-shifting framework used in Title VII employment discrimination cases.5 See McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802 (1973).

2017See Vaughan, 542 N.W.2d at 539 ; Boelman, 522 N.W.2d at 79 .

2014See, e.g., Vaughan v. Must, Inc., 542 N.W.2d 533, 538 (Iowa 1996) (describing the so-called McDonnell Douglas burden-shifting framework common to employment discrimination litigation).

2022See Hedlund, 930 N.W.2d at 719 n.8. (“In Hawkins v. Grinnell Regional Medical Center, 929 N.W.2d 261, 272 (Iowa 2019), where an age discrimination case went to trial, we held that ‘we no longer rely on the McDonnell Douglas burden-shifting analysis and determin[ing]-factor standard when instructing the jury.’ We did not disturb our prior law as it applies to summary judgment.”).

2019In Hawkins v. Grinnell Regional Medical Center , 929 N.W.2d 261 , 272 (Iowa 2019), where an age discrimination case went to trial, we held that "we no longer rely on the McDonnell Douglas burden-shifting analysis and determin[ing]-factor standard when instructing the jury." We did not disturb our prior law as it applies to summary judgment.

2022See Hedlund, 930 N.W.2d at 719 n.8. (“In Hawkins v. Grinnell Regional Medical Center, 929 N.W.2d 261, 272 (Iowa 2019), where an age discrimination case went to trial, we held that ‘we no longer rely on the McDonnell Douglas burden-shifting analysis and determin[ing]-factor standard when instructing the jury.’ We did not disturb our prior law as it applies to summary judgment.”).

2019Likewise, in Brady v. Cumberland County , the Maine Supreme Judicial Court held the McDonnell Douglas burden-shifting framework inapposite to a mixed-motive claim for whistleblower retaliation. 126 A.3d 1145 , 1154 (Me. 2015). "[I]n a summary judgment motion in a [whistleblower protection act] retaliation case," the Brady court explained, "it is unnecessary to shift the burden of production pursuant to McDonnell Douglas once the plaintiff ... has presented the requisite evidence that the adverse employment action was motivated at least in part by retaliatory intent." Id. "[I]f the employee pre

2019Likewise, in Brady v. Cumberland County , the Maine Supreme Judicial Court held the McDonnell Douglas burden-shifting framework inapposite to a mixed-motive claim for whistleblower retaliation. 126 A.3d 1145 , 1154 (Me. 2015). "[I]n a summary judgment motion in a [whistleblower protection act] retaliation case," the Brady court explained, "it is unnecessary to shift the burden of production pursuant to McDonnell Douglas once the plaintiff ... has presented the requisite evidence that the adverse employment action was motivated at least in part by retaliatory intent." Id. "[I]f the employee pre

2019See, e.g. , McQuistion v. City of Clinton , 872 N.W.2d 817 , 828-29 (Iowa 2015) (applying the McDonnell Douglas framework at summary judgment when indirect evidence is used to infer discrimination under the ICRA); Jones v. Univ. of Iowa , 836 N.W.2d 127 , 147-48 (Iowa 2013) (affirming grant of summary judgment under the McDonnell Douglas framework for race and gender discrimination claim under Title VII); Smidt , 695 N.W.2d at 14 (invoking McDonnell Douglas framework because plaintiff offered no direct evidence of discriminatory intent). 8 We do not need to decide this issue because, either wa

2019See, e.g. , McQuistion v. City of Clinton , 872 N.W.2d 817 , 828-29 (Iowa 2015) (applying the McDonnell Douglas framework at summary judgment when indirect evidence is used to infer discrimination under the ICRA); Jones v. Univ. of Iowa , 836 N.W.2d 127 , 147-48 (Iowa 2013) (affirming grant of summary judgment under the McDonnell Douglas framework for race and gender discrimination claim under Title VII); Smidt , 695 N.W.2d at 14 (invoking McDonnell Douglas framework because plaintiff offered no direct evidence of discriminatory intent). 8 We do not need to decide this issue because, either wa

2017See id.

2017See id.

2017See Vaughan, 542 N.W.2d at 539 ; Boelman, 522 N.W.2d at 79 .

2003Under the McDonnell Douglas burden shifting analysis, “a plaintiff's prima facie case, combined with sufficient evidence to find that the employer’s asserted justification is false, may permit the trier of fact to conclude that the employer unlawfully discriminated.” Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 148 , 120 S.Ct. 2097, 2109 , 147 L.Ed.2d 105, 120 (2000); accord Casey's Gen.

2003Under the McDonnell Douglas burden shifting analysis, “a plaintiff's prima facie case, combined with sufficient evidence to find that the employer’s asserted justification is false, may permit the trier of fact to conclude that the employer unlawfully discriminated.” Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 148 , 120 S.Ct. 2097, 2109 , 147 L.Ed.2d 105, 120 (2000); accord Casey's Gen.

2003Stores, *742 Inc. v. Blackford, 661 N.W.2d 515, 519-20 (Iowa 2003).