public policy exception in Iowa

2015See Springer v. Weeks & Leo Co., 429 N.W.2d 558, 560 (Iowa 1988) (adopting the public-policy exception in Iowa).

2013See Springer v. Weeks & Leo Co., 429 N.W.2d 558, 560 (Iowa 1988) (adopting the public-policy exception in Iowa).

2024See, e.g., Jones v. Univ. of Iowa, 836 N.W.2d 127, 144 (Iowa 16 2013) (“The narrow public-policy exception to the at-will employment doctrine ‘limits an employer’s discretion to discharge an at-will employee when the discharge would undermine a clearly defined and well-recognized public policy of the state.’ ” (quoting Berry v. Liberty Holdings, Inc., 803 N.W.2d 106, 109 (Iowa 2011))); Dorshkind v. Oak Park Place of Dubuque II, L.L.C., 835 N.W.2d 293, 303 (Iowa 2013) (“Thus, the exception is narrowly circumscribed to only those policies clearly defined and well-recognized to protect those with

2023Jasper’s broad statements about the principles supporting liability for wrongful discharge cannot be divorced from the parameters underlying the tort. 30 See Dorshkind v. Oak Park Place of Dubuque II, L.L.C., 835 N.W.2d 293, 303 (Iowa 2013) (“We cautiously identify policies to support an action for wrongful discharge under the public-policy exception . . . [to avoid] ‘unwittingly transform[ing] the public policy exception into a “good faith and fair dealing” exception, a standard we have repeatedly rejected.’ ” (quoting Fitzgerald v. Salsbury Chem., Inc., 613 N.W.2d 275, 283 (Iowa 2000) (en ba

2024See, e.g., Jones v. Univ. of Iowa, 836 N.W.2d 127, 144 (Iowa 16 2013) (“The narrow public-policy exception to the at-will employment doctrine ‘limits an employer’s discretion to discharge an at-will employee when the discharge would undermine a clearly defined and well-recognized public policy of the state.’ ” (quoting Berry v. Liberty Holdings, Inc., 803 N.W.2d 106, 109 (Iowa 2011))); Dorshkind v. Oak Park Place of Dubuque II, L.L.C., 835 N.W.2d 293, 303 (Iowa 2013) (“Thus, the exception is narrowly circumscribed to only those policies clearly defined and well-recognized to protect those with

2024See, e.g., Jones v. Univ. of Iowa, 836 N.W.2d 127, 144 (Iowa 16 2013) (“The narrow public-policy exception to the at-will employment doctrine ‘limits an employer’s discretion to discharge an at-will employee when the discharge would undermine a clearly defined and well-recognized public policy of the state.’ ” (quoting Berry v. Liberty Holdings, Inc., 803 N.W.2d 106, 109 (Iowa 2011))); Dorshkind v. Oak Park Place of Dubuque II, L.L.C., 835 N.W.2d 293, 303 (Iowa 2013) (“Thus, the exception is narrowly circumscribed to only those policies clearly defined and well-recognized to protect those with

2025We echoed an earlier case’s warning that “[a]ny effort to evaluate the public policy exception with generalized concepts of fairness and justice will result in an elimination of the at-will doctrine itself” and “could unwittingly transform the public policy exception into a ‘good faith and fair dealing’ exception, a standard we have repeatedly rejected.” Id. (quoting Fitzgerald, 613 N.W.2d at 283 ).

2025“The public-policy exception to the at-will employment doctrine limits an employer’s discretion to discharge an at-will employee when the discharge would undermine a clearly defined and well-recognized public policy of the state.” Id.

2024See, e.g., Jones v. Univ. of Iowa, 836 N.W.2d 127, 144 (Iowa 16 2013) (“The narrow public-policy exception to the at-will employment doctrine ‘limits an employer’s discretion to discharge an at-will employee when the discharge would undermine a clearly defined and well-recognized public policy of the state.’ ” (quoting Berry v. Liberty Holdings, Inc., 803 N.W.2d 106, 109 (Iowa 2011))); Dorshkind v. Oak Park Place of Dubuque II, L.L.C., 835 N.W.2d 293, 303 (Iowa 2013) (“Thus, the exception is narrowly circumscribed to only those policies clearly defined and well-recognized to protect those with

2023See, e.g., Jones v. Univ. of Iowa, 836 N.W.2d 127, 144 (Iowa 2013) (“The narrow public-policy exception to the at-will employment doctrine ‘limits an employer’s discretion to discharge an at-will employee when the discharge would undermine a clearly defined and well-recognized public policy of the state.’ ” (quoting Berry v. Liberty Holdings, Inc., 803 N.W.2d 106, 109 (Iowa 2011))); Dorshkind v. Oak Park Place of Dubuque II, L.L.C., 835 N.W.2d 293, 303 (Iowa 2013) (“Thus, the exception is narrowly circumscribed to only those policies clearly defined and well-recognized to protect those with a

2013“The use of statutes maintains the narrow public-policy exception and ‘provide[s] the essential notice to employers and employees of conduct that . . . can lead to tort liability.’ ” Ballalatak, 781 N.W.2d at 277 (quoting Jasper, 764 N.W.2d at 763 ).

2013“The use of statutes maintains the narrow public-policy exception and ‘provide[s] the essential notice to employers and employees of conduct that ... can lead to tort liability.’ ” Ballalatak, 781 N.W.2d at 277 (quoting Jasper, 764 N.W.2d at 763 ).

2013“The use of statutes maintains the narrow public-policy exception and ‘provide[s] the essential notice to employers and employees of conduct that . . . can lead to tort liability.’ ” Ballalatak, 781 N.W.2d at 277 (quoting Jasper, 764 N.W.2d at 763 ).

2013“The use of statutes maintains the narrow public-policy exception and ‘provide[s] the essential notice to employers and employees of conduct that ... can lead to tort liability.’ ” Ballalatak, 781 N.W.2d at 277 (quoting Jasper, 764 N.W.2d at 763 ).

2017Id. at 196.

1989As noted in Northrup v. Farmland Industries, Inc., 372 N.W.2d at 196 : [The supreme court] has never expressly recognized a public policy exception [to the employment at will doctrine], although we recently noted its increasing acceptance in other jurisdictions.

2003Borschel v. City of Perry, 512 N.W.2d 565, 568 (Iowa 1994).

1997Borschel v. City of Perry, 512 N.W.2d 565, 567 (Iowa 1994).

2010The public policy for this rule “is founded not on a belief that the evidence is irrelevant, but rather on a fear that juries will tend to give it excessive weight, and on a fundamental sense that no one should be convicted of a crime based on his or her previous misdeeds.” State v. Sullivan, 679 N.W.2d 19, 24 (Iowa 2004) (quoting United States v. Daniels, 770 F.2d 1111, 1116 (D.C.Cir.1985)).

2010The public policy for this rule “is founded not on a belief that the evidence is irrelevant, but rather on a fear that juries will tend to give it excessive weight, and on a fundamental sense that no one should be convicted of a crime based on his or her previous misdeeds.” State v. Sullivan, 679 N.W.2d 19, 24 (Iowa 2004) (quoting United States v. Daniels, 770 F.2d 1111, 1116 (D.C.

2010The public policy for this rule “is founded not on a belief that the evidence is irrelevant, but rather on a fear that juries will tend to give it excessive weight, and on a fundamental sense that no one should be convicted of a crime based on his or her previous misdeeds.” State v. Sullivan, 679 N.W.2d 19, 24 (Iowa 2004) (quoting United States v. Daniels, 770 F.2d 1111, 1116 (D.C.Cir.1985)).

2010The public policy for this rule “is founded not on a belief that the evidence is irrelevant, but rather on a fear that juries will tend to give it excessive weight, and on a fundamental sense that no one should be convicted of a crime based on his or her previous misdeeds.” State v. Sullivan, 679 N.W.2d 19, 24 (Iowa 2004) (quoting United States v. Daniels, 770 F.2d 1111, 1116 (D.C.

2009See, e.g., Lara v. Thomas, 512 N.W.2d 777, 782 (Iowa 1994); Springer v. Weeks & Leo Co., 429 N.W.2d 558, 560 (Iowa 1988).

2009See, e.g., Lara v. Thomas, 512 N.W.2d 777, 782 (Iowa 1994); Springer v. Weeks & Leo Co., 429 N.W.2d 558, 560 (Iowa 1988).

1989See Abrisz [v. Pulley Freight Lines], 270 N.W.2d at 455 . ...

1985See Abrisz, 270 N.W.2d at 455 .

2025We echoed an earlier case’s warning that “[a]ny effort to evaluate the public policy exception with generalized concepts of fairness and justice will result in an elimination of the at-will doctrine itself” and “could unwittingly transform the public policy exception into a ‘good faith and fair dealing’ exception, a standard we have repeatedly rejected.” Id. (quoting Fitzgerald, 613 N.W.2d at 283 ).

2013Fitzgerald, 613 N.W.2d at 283 (citations omitted); accord Lloyd v. Drake Univ., 686 N.W.2d 225, 230-31 (Iowa 2004) (rejecting a wrongful-discharge claim lodged by a security guard who was fired after forcibly restraining a student suspected of assault because the asserted public policy against crime is generalized, not “clearly defined”).

2009Gantt v. Sentry Ins., 1 Cal.4th 1083 , 4 Cal.Rptr.2d 874 , 824 P.2d 680, 686-87 (1992), overruled on other grounds by Green v. Ralee Eng’g Co., 19 Cal.4th 66 , 78 Cal.Rptr.2d 16 , 960 P.2d 1046 (1998); see also Rocky Mountain Hosp. & Med.

2009Gantt v. Sentry Ins., 1 Cal.4th 1083 , 4 Cal.Rptr.2d 874 , 824 P.2d 680, 686-87 (1992), overruled on other grounds by Green v. Ralee Eng’g Co., 19 Cal.4th 66 , 78 Cal.Rptr.2d 16 , 960 P.2d 1046 (1998); see also Rocky Mountain Hosp. & Med.

1975And the Boyer majority never disputed the court’s right to strike down the immunity barrier judicially interposed to thwart injured persons’ remedies against municipalities, it simply took the position the matter was “a public policy doctrine * * * more appropriately left to the legislature.” 256 Iowa at 348 , 127 N.W.2d at 612 .

1975And the Boyer majority never disputed the court’s right to strike down the immunity barrier judicially interposed to thwart injured persons’ remedies against municipalities, it simply took the position the matter was “a public policy doctrine * * * more appropriately left to the legislature.” 256 Iowa at 348 , 127 N.W.2d at 612 .

2019See Moser v. County of Black Hawk, 300 N.W.2d 150, 152, 153 (Iowa 1981) (affirming dismissal of malicious prosecution claim against county based on county 7 attorney’s entitlement to absolute immunity); Burr v. City of Cedar Rapids, 286 N.W.2d 393, 396 (Iowa 1979) (“The public policy which requires immunity for the prosecuting attorney, also requires immunity for both the state and the county for acts of judicial and quasi-judicial officers in the performance of the duties which rest upon them . . . .” (quoting Gartin v. Jefferson County, 281 N.W.2d 25, 31 (Iowa Ct. App. 1979))).

2019See Moser v. County of Black Hawk , 300 N.W.2d 150 , 152, 153 (Iowa 1981) (affirming dismissal of malicious prosecution claim against county based on county attorney's entitlement to absolute immunity); Burr v. City of Cedar Rapids , 286 N.W.2d 393 , 396 (Iowa 1979) ("The public policy which requires immunity for the prosecuting attorney, also requires immunity for both the state and the county for acts of judicial and quasi-judicial officers in the performance of the duties which rest upon them ...." (quoting Gartin v. Jefferson County , 281 N.W.2d 25 , 31 (Iowa Ct. App. 1979) )).

2019See Moser v. County of Black Hawk, 300 N.W.2d 150, 152, 153 (Iowa 1981) (affirming dismissal of malicious prosecution claim against county based on county 7 attorney’s entitlement to absolute immunity); Burr v. City of Cedar Rapids, 286 N.W.2d 393, 396 (Iowa 1979) (“The public policy which requires immunity for the prosecuting attorney, also requires immunity for both the state and the county for acts of judicial and quasi-judicial officers in the performance of the duties which rest upon them . . . .” (quoting Gartin v. Jefferson County, 281 N.W.2d 25, 31 (Iowa Ct. App. 1979))).

2019See Moser v. County of Black Hawk , 300 N.W.2d 150 , 152, 153 (Iowa 1981) (affirming dismissal of malicious prosecution claim against county based on county attorney's entitlement to absolute immunity); Burr v. City of Cedar Rapids , 286 N.W.2d 393 , 396 (Iowa 1979) ("The public policy which requires immunity for the prosecuting attorney, also requires immunity for both the state and the county for acts of judicial and quasi-judicial officers in the performance of the duties which rest upon them ...." (quoting Gartin v. Jefferson County , 281 N.W.2d 25 , 31 (Iowa Ct. App. 1979) )).

2019See Moser v. County of Black Hawk, 300 N.W.2d 150, 152, 153 (Iowa 1981) (affirming dismissal of malicious prosecution claim against county based on county 7 attorney’s entitlement to absolute immunity); Burr v. City of Cedar Rapids, 286 N.W.2d 393, 396 (Iowa 1979) (“The public policy which requires immunity for the prosecuting attorney, also requires immunity for both the state and the county for acts of judicial and quasi-judicial officers in the performance of the duties which rest upon them . . . .” (quoting Gartin v. Jefferson County, 281 N.W.2d 25, 31 (Iowa Ct. App. 1979))).

2019See Moser v. County of Black Hawk , 300 N.W.2d 150 , 152, 153 (Iowa 1981) (affirming dismissal of malicious prosecution claim against county based on county attorney's entitlement to absolute immunity); Burr v. City of Cedar Rapids , 286 N.W.2d 393 , 396 (Iowa 1979) ("The public policy which requires immunity for the prosecuting attorney, also requires immunity for both the state and the county for acts of judicial and quasi-judicial officers in the performance of the duties which rest upon them ...." (quoting Gartin v. Jefferson County , 281 N.W.2d 25 , 31 (Iowa Ct. App. 1979) )).

2018Health Ctrs., Inc., 394 F. App’x 987 , 992–93 (4th Cir. 2010) (per curiam) (Under South Carolina law, the plaintiff “could not avail herself of the public policy exception [for wrongful discharge in violation of public policy] because she was not an at-will employee of” her employer.); Egan v. Wells Fargo Alarm Servs., 23 F.3d 1444, 1446 (8th Cir. 1994) (“[U]nder Missouri law, contract employees—those employed for a ‘definite term’ and who cannot be discharged without just cause—have no state law cause of action for wrongful discharge” because the public-policy exception is limited to at- will

2018Health Ctrs., Inc. , 394 F. App'x 987 , 992-93 (4th Cir. 2010) (per curiam) (Under South Carolina law, the plaintiff "could not avail herself of the public policy exception [for wrongful discharge in violation of public policy] because she was not an at-will employee of" her employer.); Egan v. Wells Fargo Alarm Servs. , 23 F.3d 1444 , 1446 (8th Cir. 1994) ("[U]nder Missouri law, contract employees-those employed for a 'definite term' and who cannot be discharged without just cause-have no state law cause of action for wrongful discharge" because the public-policy exception is limited to at-wi

2018See, e.g. , Wisehart v. Meganck , 66 P.3d 124 , 128 (Colo. Ct. App. 2002) ("[L]aw will not punish a party for doing by misdirection that which it has a right to do forthrightly." (citation omitted) ); Andress v. Augusta Nursing Facilities, Inc. , 275 S.E.2d 368 , 369 (Ga. Ct. App. 1980) ("[A]llegations as to improper motive for firing ... are legally irrelevant and present no genuine issues of material fact." (citations omitted) ); Clark v. Acco Systems, Inc. , 899 So. 2d 783 , 787 (La.