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Iowa Supreme Court Addresses Standards for Employment Discrimination Claims

• Jun 16, 2019

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Legal Update by Attorney Clarissa Bierstedt

In the case of Hawkins v. Grinnell Regional Medical Center, a terminated employee (Hawkins) sued his former employer (Grinnell) alleging they discriminated against him because of his age and his disability – i.e., his status as a cancer patient. Grinnell contended it did not terminate Hawkins for a discriminatory reason, but rather due to his poor job performance. The case proceeded to trial and the jury returned a verdict for Hawkins. Grinnell appealed the verdict.

In the Supreme Court’s decision, the Court found the district court erred in admitting hearsay and remanded for a new trial. Of significance, the Court also clarified Iowa’s standards for employment discrimination cases. Iowa has adopted the motivating factor standard from the case of Price Waterhouse v. Hopkins, 490 U.S. 228, 258, 109 S. Ct. 1775, 1795 (1989). The Price Waterhouse case established that when a Title VII plaintiff proves that a discriminatory factor played a motivating part in the employer’s decision to terminate an employee (i.e., there were mixed motives), the employer may avoid liability by presenting evidence that it would have made the same decision in the absence of the discriminatory motive.

The Iowa Supreme Court’s decision is significant in that it clarifies that a defendant in an employment discrimination case can avoid liability “by proving by a preponderance of the evidence that it would have made the same decision even if it had not taken the plaintiff’s gender [or other protected characteristics] into account.” The defendant is entitled to a jury instruction on this defense as long as the defense was properly pled and proved at trial.

 

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