In 2006, the plaintiff in this case was injured when the vehicle he was driving was struck by a concrete pumper truck on his way home from work. The plaintiff filed a personal injury suit against the company that owned the truck for the injuries he sustained and subsequently settled the suit. Here, the owner of company owning the truck was also a partial owner of the company the plaintiff worked for. Nine months after the plaintiff settled the personal injury suit, his employment with the defendant was terminated. The plaintiff filed a suit against his former employer claiming wrongful termination in violation of Iowa’s comparative fault statute (Iowa Code §668). The plaintiff claimed that even though he was an at-will employee, he was engaging in a “protected activity” by filing the personal injury suit against the company owning the truck.
The defendant responded by filing a motion to dismiss, arguing that the plaintiff failed to show a “clearly-defined public policy” that protected “an employee’s right to file a civil lawsuit against someone other than his or her employer.” The trial court granted the defendant employer’s motion to dismiss. On appeal, the Iowa Court of Appeals reversed the trial court’s ruling and remanded the case. The defendant’s application for further review was granted by the Iowa Supreme Court.
The sole issue before the Iowa Supreme Court was whether Iowa’s comparative fault statute limits an employer’s discretion to discharge an at-will employee. The plaintiff argued that §668 clearly protects people from termination when they bring actions to “seek redress for personal injuries caused by the negligence of another.” The Iowa Supreme Court disagreed, holding that the Code provision does not “express a clearly-defined and well-recognized public policy of this state that would limit an employer’s discretion to discharge an at-will employee.” The Court vacated the ruling of the Iowa Court of Appeals ruling, and reinstated the trial court’s dismissal of the plaintiff’s suit for wrongful termination.
According to the appellate court, Iowa is an at-will employment state- meaning that absent a valid contract of employment, the employer-employee relationship may be terminated by either party at any time for any reason (or no reason at all). However, Iowa has adopted a narrow public policy exception to the at-will doctrine that limits the employer’s discretion to terminate employment when the termination would “undermine a clearly-defined and well-recognized public policy of the state.” Here, the appellate court found that Iowa’s comparative fault statute does not clearly articulate a public policy precluding the plaintiff’s termination for filing a personal injury lawsuit against a company under common ownership with his employer. Iowa Code §668 attempts to regulate private conduct and does not clearly implicate public policy concerns. Berry v. Liberty Holdings, Inc. a/k/a Liberty Ready Mix, No. 10-0094, 2011 Iowa Sup. LEXIS 69 (Iowa Sup. Ct. Sept. 9, 2011).