Already have an account? Sign in instead.
You stay signed in for 30 days on this browser.
Continue with Google Continue with MicrosoftNo account yet? Create a free one.
We sent a six-digit code.
It expires in ten minutes, works once, and only in this browser. Five wrong tries void it. Send another code.
Your account is live and the Cloudflare checks are off for this browser.
10 Iowa opinions name it 1 courts 2002–2024 3 in the last five years
The cases below were cited by Iowa courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Cubit v. Mahaska Countygreen2 sentences2024The footnote said: “Because we find the ‘arising out of’ alternative of [the emergency response exception] dispositive, we do not consider whether the negligent supervision claim is ‘based upon . . . an act or omission in connection with an emergency response.’ ” Id. at 782 n.1 (omission in original) (quoting Iowa Code § 670.4 (11) (1999)). 12 In short, we agree with Aidan that Cubit is not particularly relevant to our analysis here. 2024The footnote said: “Because we find the ‘arising out of’ alternative of [the emergency response exception] dispositive, we do not consider whether the negligent supervision claim is ‘based upon . . . an act or omission in connection with an emergency response.’ ” Id. at 782 n.1 (omission in original) (quoting Iowa Code § 670.4 (11) (1999)). 12 In short, we agree with Aidan that Cubit is not particularly relevant to our analysis here. | 1 | 3 |
Estate of Harris v. Papa John's Pizzagreen2 sentences2023In Harris, we saw “no reason to carve out an exception to the general rule of preemption” for a negligent supervision claim premised on failing to protect an employee when his supervisor gave him a “chest shot”2 after the employee informed a coemployee that the supervisor was sleeping with a subordinate, which was against company policy. 679 N.W.2d at 681–82. 2018Estate of Harris v. Papa John's Pizza , 679 N.W.2d 673 , 680 (Iowa 2004) (quoting Stricker v. Cessford Constr. | 1 | 3 |
Graves v. Iowa Lakes Community Collegegreen2 sentences2023In Graves v. Iowa Lakes Community College, we declined to follow cases from other jurisdictions that had recognized such claims where the coworker caused a physical injury, unlike the issue in Graves, which involved a 10 claim of negligent supervision premised on fabricated performance reviews by the plaintiff’s supervisor that allegedly resulted in the wrongful termination of the plaintiff. 639 N.W.2d 22, 25 (Iowa 2002) (“Because Graves does not assert any physical injury it is unnecessary for us to decide whether a negligent supervision claim is available to a fellow employee.”), overruled b 2004In Graves, we affirmed the dismissal of a negligent supervision claim because the plaintiff failed to assert any physical injuries. 639 N.W.2d at 25 . | 1 | 2 |
Schoff v. Combined Insurance Co. of Americagreen1 sentence2005Co. of Am., 604 N.W.2d 43, 53 (Iowa 1999) (citation omit *113 ted); accord Cubit v. Mahaska County, 677 N.W.2d 777, 784-85 (Iowa 2004). | 1 | 1 |
Susie Myers Perkins, Administratrix of the Estate of John David Perkins, Jr., Deceased v. United Statesgreen2 sentences2004Therefore, the negligent supervision claim is one “arising out of an act or omission in connection with an emergency response,” within the scope of Iowa Code section 670.4(H). 2 See Perkins v. United States, 55 F.3d 910, 916 (4th Cir.1995) (stating with respect to exception to Federal Tort Claims Act: “An allegation of ‘negligent supervision’ will not render an otherwise unactionable claim actionable so long as the negligent supervision claim depends on activity of the supervised agent which is itself immune.”); Dist. of Columbia v. Walker, 689 A.2d 40, 50 (D.C.Ct.App.1997) (interpreting statu 2004Therefore, the negligent supervision claim is one “arising out of an act or omission in connection with an emergency response,” within the scope of Iowa Code section 670.4(H). 2 See Perkins v. United States, 55 F.3d 910, 916 (4th Cir.1995) (stating with respect to exception to Federal Tort Claims Act: “An allegation of ‘negligent supervision’ will not render an otherwise unactionable claim actionable so long as the negligent supervision claim depends on activity of the supervised agent which is itself immune.”); Dist. of Columbia v. Walker, 689 A.2d 40, 50 (D.C.Ct.App.1997) (interpreting statu | 1 | 1 |
District of Columbia v. Walkergreen2 sentences2004Therefore, the negligent supervision claim is one “arising out of an act or omission in connection with an emergency response,” within the scope of Iowa Code section 670.4(H). 2 See Perkins v. United States, 55 F.3d 910, 916 (4th Cir.1995) (stating with respect to exception to Federal Tort Claims Act: “An allegation of ‘negligent supervision’ will not render an otherwise unactionable claim actionable so long as the negligent supervision claim depends on activity of the supervised agent which is itself immune.”); Dist. of Columbia v. Walker, 689 A.2d 40, 50 (D.C.Ct.App.1997) (interpreting statu 2004Therefore, the negligent supervision claim is one “arising out of an act or omission in connection with an emergency response,” within the scope of Iowa Code section 670.4(H). 2 See Perkins v. United States, 55 F.3d 910, 916 (4th Cir.1995) (stating with respect to exception to Federal Tort Claims Act: “An allegation of ‘negligent supervision’ will not render an otherwise unactionable claim actionable so long as the negligent supervision claim depends on activity of the supervised agent which is itself immune.”); Dist. of Columbia v. Walker, 689 A.2d 40, 50 (D.C.Ct.App.1997) (interpreting statu | 1 | 1 |
Nylund v. Carson Citygreen2 sentences2004Therefore, the negligent supervision claim is one “arising out of an act or omission in connection with an emergency response,” within the scope of Iowa Code section 670.4(H). 2 See Perkins v. United States, 55 F.3d 910, 916 (4th Cir.1995) (stating with respect to exception to Federal Tort Claims Act: “An allegation of ‘negligent supervision’ will not render an otherwise unactionable claim actionable so long as the negligent supervision claim depends on activity of the supervised agent which is itself immune.”); Dist. of Columbia v. Walker, 689 A.2d 40, 50 (D.C.Ct.App.1997) (interpreting statu 2004Therefore, the negligent supervision claim is one “arising out of an act or omission in connection with an emergency response,” within the scope of Iowa Code section 670.4(H). 2 See Perkins v. United States, 55 F.3d 910, 916 (4th Cir.1995) (stating with respect to exception to Federal Tort Claims Act: “An allegation of ‘negligent supervision’ will not render an otherwise unactionable claim actionable so long as the negligent supervision claim depends on activity of the supervised agent which is itself immune.”); Dist. of Columbia v. Walker, 689 A.2d 40, 50 (D.C.Ct.App.1997) (interpreting statu | 1 | 1 |
Godar v. Edwardsgreen1 sentence2002Godar v. Edwards, 588 N.W.2d 701, 708 (Iowa 1999); see Mork Clinic v. Fireman’s Fund Ins. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Iowa. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Kiesau v. Bantz
green
2 sentences2023In Graves v. Iowa Lakes Community College, we declined to follow cases from other jurisdictions that had recognized such claims where the coworker caused a physical injury, unlike the issue in Graves, which involved a 10 claim of negligent supervision premised on fabricated performance reviews by the plaintiff’s supervisor that allegedly resulted in the wrongful termination of the plaintiff. 639 N.W.2d 22, 25 (Iowa 2002) (“Because Graves does not assert any physical injury it is unnecessary for us to decide whether a negligent supervision claim is available to a fellow employee.”), overruled b 2023While we later clarified in Kiesau v. Bantz that there is no physical-injury predicate for negligent supervision claims generally, see 686 N.W.2d at 172–73 (concluding that a physical-injury requirement was contrary to Restatement (Second) section 213, upon which the tort was premised and led to absurd distinctions); that case involved a claim by a former employee premised on events that postdated her employment, see id. (addressing negligent supervision claim premised on defamation and invasion of privacy allegations against a former coemployee who distributed digitally-altered photos of the | 1 | 2023–2023 |
Stricker v. Cessford Construction Co.
green
1 sentence2023Co., 179 F. Supp. 2d 987 , 1017–19 (N.D. | 1 | 2023–2023 |
Sibley v. Kaiser Foundation Health Plan
green
1 sentence2004Because the plaintiff in Gmves did not suffer a physical injury, we did not “decide whether a negligent supervision claim is available to a fellow employee.” Id. | 1 | 2004–2004 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.