vicarious liability standard (Iowa) · Go Syfert
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vicarious liability standard in Iowa

7 Iowa opinions name it 2 courts 1991–2026 2 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.

Followed or applied (11)

CaseFollowedCited
Curry v. District of Columbiagreen
cadc · 1999 · cited in 2 Iowa opinions naming this issue, 2017–2017
2 sentences

2017Curry v. District of Columbia, 195 F.3d 654, 660 (D.C.

2017Curry v. District of Columbia, 195 F.3d 654, 660 (D.C.

22
Reed v. Cedar Countygreen
iand · 2007 · cited in 2 Iowa opinions naming this issue, 2017–2017
2 sentences

2017See, e.g., Reed v. Cedar County, 474 F. Supp. 2d 1045 , 1061–62 (N.D.

2017See, e.g., Reed v. Cedar County, 474 F. Supp. 2d 1045 , 1061–62 (N.D.

22
Farmland Foods, Inc. v. Dubuque Human Rights Commissiongreen
iowa · 2003 · cited in 2 Iowa opinions naming this issue, 2017–2017
2 sentences

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 .

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 .

22
Deboom v. Raining Rose, Inc.green
iowa · 2009 · cited in 2 Iowa opinions naming this issue, 2017–2017
2 sentences

2017Because the ICRA hostile-work-environment claim is modeled after its Title VII counterpart, we consider federal law instructive. 2 Boyle, 710 N.W.2d at 749–50 (recognizing that Title VII hostile-work-environment claim has the same elements as ICRA claim); see also DeBoom, 772 N.W.2d at 7 (“When interpreting discrimination claims under Iowa Code chapter 216, we turn 2It has been suggested that we should not rely on federal law because Iowa civil rights statutes were enacted before Title VII.

2017Because the ICRA hostile-work-environment claim is modeled after its Title VII counterpart, we consider federal law instructive. 2 Boyle, 710 N.W.2d at 749–50 (recognizing that Title VII hostile-work-environment claim has the same elements as ICRA claim); see also DeBoom, 772 N.W.2d at 7 (“When interpreting discrimination claims under Iowa Code chapter 216, we turn 2It has been suggested that we should not rely on federal law because Iowa civil rights statutes were enacted before Title VII.

22
Boyle v. Alum-Line, Inc.green
iowa · 2006 · cited in 2 Iowa opinions naming this issue, 2017–2017
2 sentences

2017Because the ICRA hostile-work-environment claim is modeled after its Title VII counterpart, we consider federal law instructive. 2 Boyle, 710 N.W.2d at 749–50 (recognizing that Title VII hostile-work-environment claim has the same elements as ICRA claim); see also DeBoom, 772 N.W.2d at 7 (“When interpreting discrimination claims under Iowa Code chapter 216, we turn 2It has been suggested that we should not rely on federal law because Iowa civil rights statutes were enacted before Title VII.

2017Because the ICRA hostile-work-environment claim is modeled after its Title VII counterpart, we consider federal law instructive. 2 Boyle, 710 N.W.2d at 749–50 (recognizing that Title VII hostile-work-environment claim has the same elements as ICRA claim); see also DeBoom, 772 N.W.2d at 7 (“When interpreting discrimination claims under Iowa Code chapter 216, we turn 2It has been suggested that we should not rely on federal law because Iowa civil rights statutes were enacted before Title VII.

12
Rosauer Corporation v. Sapp Development, L.L.C. Todd Sapp Whispering Creek, L.L.C. And W.C. Development, Inc.green
iowa · 2014 · cited in 1 Iowa opinions naming this issue, 2020–2020
1 sentence

2020See Rosauer Corp. v. Sapp Dev., L.L.C., 856 N.W.2d 906, 907 (Iowa 2014) (noting court of appeals “appropriately” deferred to supreme court on expansion of implied warranty).

11
Tina Haskenhoff v. Homeland Energy Solutions, LLCgreen
iowa · 2017 · cited in 1 Iowa opinions naming this issue, 2018–2018
2 sentences

2018Haskenhoff v. Homeland Energy Sols., LLC, 897 N.W.2d 553, 574 (Iowa 2017).

2018Haskenhoff v. Homeland Energy Sols., LLC , 897 N.W.2d 553 , 574 (Iowa 2017).

11
Truhitte v. French Hospitalgreen
calctapp · 1982 · cited in 1 Iowa opinions naming this issue, 1991–1991
2 sentences

1991And although some states still apply the doctrine, see, e.g., Young by and through Young v. Carpenter, 694 P.2d 861, 863 (Colo.App.1984), and California courts are split on the issue, compare Schultz by and through Schultz v. Mutch, 211 Cal.Rptr. 445 , 450 (1985) (Court of Appeal opinion endorsing doctrine; California Supreme Court denied hearing and ordered no official publication), with Truhitte v. French Hosp., 128 Cal.App.3d 332, 348-49 , 180 Cal.Rptr. 152, 160 (1982) (disapproving doctrine), the majority of courts shun this rigid doctrine of vicarious liability.

1991And although some states still apply the doctrine, see, e.g., Young by and through Young v. Carpenter, 694 P.2d 861, 863 (Colo.App.1984), and California courts are split on the issue, compare Schultz by and through Schultz v. Mutch, 211 Cal.Rptr. 445 , 450 (1985) (Court of Appeal opinion endorsing doctrine; California Supreme Court denied hearing and ordered no official publication), with Truhitte v. French Hosp., 128 Cal.App.3d 332, 348-49 , 180 Cal.Rptr. 152, 160 (1982) (disapproving doctrine), the majority of courts shun this rigid doctrine of vicarious liability.

11
Young by and Through Young v. Carpentergreen
coloctapp · 1984 · cited in 1 Iowa opinions naming this issue, 1991–1991
1 sentence

1991And although some states still apply the doctrine, see, e.g., Young by and through Young v. Carpenter, 694 P.2d 861, 863 (Colo.App.1984), and California courts are split on the issue, compare Schultz by and through Schultz v. Mutch, 211 Cal.Rptr. 445 , 450 (1985) (Court of Appeal opinion endorsing doctrine; California Supreme Court denied hearing and ordered no official publication), with Truhitte v. French Hosp., 128 Cal.App.3d 332, 348-49 , 180 Cal.Rptr. 152, 160 (1982) (disapproving doctrine), the majority of courts shun this rigid doctrine of vicarious liability.

11
Sparger v. Worley Hospital, Inc.green
tex · 1977 · cited in 1 Iowa opinions naming this issue, 1991–1991
1 sentence

1991See Sparger v. Worley Hosp., Inc., 547 S.W.2d 582, 584 (Tex.1977) (rejecting captain of ship concept in favor of borrowed servant doctrine); Parker v. Vanderbilt Univ., 767 S.W.2d 412, 415 (Tenn.App.1988) (same).

11
Parker v. Vanderbilt Universitygreen
tennctapp · 1988 · cited in 1 Iowa opinions naming this issue, 1991–1991
1 sentence

1991See Sparger v. Worley Hosp., Inc., 547 S.W.2d 582, 584 (Tex.1977) (rejecting captain of ship concept in favor of borrowed servant doctrine); Parker v. Vanderbilt Univ., 767 S.W.2d 412, 415 (Tenn.App.1988) (same).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Iowa. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
Faragher v. City of Boca Raton green
scotus · 1998
2 sentences

2017The employer defending a vicarious liability claim may assert the Faragher–Ellerth affirmative defense by showing it: (1) “exercised reasonable care to prevent and correct promptly any . . . harassing behavior,” and (2) “that the plaintiff employee unreasonably failed to take advantage of preventive or corrective opportunities provided by the employer or to avoid harm otherwise.” Id. at 744 n.2 (quoting Faragher, 524 U.S. at 807 , 118 S. Ct. at 2293 ).

2017The employer defending a vicarious liability claim may assert the Faragher–Ellerth affirmative defense by showing it: (1) “exercised reasonable care to prevent and correct promptly any . . . harassing behavior,” and (2) “that the plaintiff employee unreasonably failed to take advantage of preventive or corrective opportunities provided by the employer or to avoid harm otherwise.” Id. at 744 n.2 (quoting Faragher, 524 U.S. at 807 , 118 S. Ct. at 2293 ).

22017–2017
Lora Stuart v. General Motors Corp. green
ca8 · 2000
2 sentences

2017The employer defending a vicarious liability claim may assert the Faragher–Ellerth affirmative defense by showing it: (1) “exercised reasonable care to prevent and correct promptly any . . . harassing behavior,” and (2) “that the plaintiff employee unreasonably failed to take advantage of preventive or corrective opportunities provided by the employer or to avoid harm otherwise.” Id. at 744 n.2 (quoting Faragher, 524 U.S. at 807 , 118 S. Ct. at 2293 ).

2017The employer defending a vicarious liability claim may assert the Faragher–Ellerth affirmative defense by showing it: (1) “exercised reasonable care to prevent and correct promptly any . . . harassing behavior,” and (2) “that the plaintiff employee unreasonably failed to take advantage of preventive or corrective opportunities provided by the employer or to avoid harm otherwise.” Id. at 744 n.2 (quoting Faragher, 524 U.S. at 807 , 118 S. Ct. at 2293 ).

22017–2017
Godar v. Edwards green
iowa · 1999
1 sentence

2026Id.

12026–2026
Ferrer v. Okbamicael red
colo · 2017
1 sentence

2026Ferrer, 390 P.3d at 845 .

12026–2026
Wolbers v. the Finley Hosp. green
iowa · 2003
1 sentence

2021Furthermore, Ward’s argument based on Wolbers required her to prove a prima facie case of medical malpractice against one of the doctor defendants to be able to assert a claim of vicarious liability against the hospital. 673 N.W.2d at 733–34 (permitting the vicarious-liability claim because of the hospital’s relationship to its emergency-response staff).

12021–2021

Where else courts name it

TX 51 (2002–2026) NY 28 (1972–2026) FL 26 (1977–2024) MI 24 (1980–2025) IL 21 (1976–2026) CA 16 (1978–2017) PA 16 (1987–2021) TN 15 (1966–2025) IN 15 (1979–2025) NJ 14 (1993–2026) AZ 13 (1992–2025) CT 13 (1999–2024) MS 12 (2004–2023) GA 12 (2000–2023) OH 11 (2005–2025) LA 8 (2004–2025) WI 8 (1996–2025) CO 7 (1968–2021) MO 7 (1995–2024) IA 7 (1991–2026) NV 6 (1978–2021) MN 6 (1961–2024) MD 4 (2013–2026) DE 4 (2015–2020) AL 4 (2005–2025) KS 4 (1983–2022) NM 4 (2012–2023) DC 4 (1997–2020) WY 3 (2001–2025) MA 3 (1983–2023) AK 3 (1980–2002) WA 3 (2013–2025) SD 3 (2000–2012) WV 3 (2001–2024) VA 3 (2005–2018) OR 2 (2008–2009) NH 2 (2006–2009) NC 2 (1999–2002) ME 2 (2009–2010) KY 2 (2001–2006) UT 2 (2011–2023) AR 2 (2013–2021)

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.

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