On June 9, 2019, the Iowa Supreme Court issued an anticipated ruling in the case of Hawkins v. Grinnell Regional Medical Center. For you legal junkies, you can read the opinion here. Gregory Hawkins, who was represented by my friend and fierce advocate for employees, Brooke Timmer, sued his former employer, Grinnell Regional Medical Center, after he was fired following years of dedicated service. Hawkins claimed he was a victim of disability discrimination and retaliation and a jury agreed, awarding Hawkins over $4 million in damages.
Many issues were presented on appeal, but the Iowa Supreme Court focused on just two. Unfortunately, the Court overturned the verdict and sent the case back for a new trial because of certain evidence that was admitted at trial. But in addition to that, the Court addressed the standards of proof that apply in most cases of employment discrimination.
The Court confirmed its long standing, but often challenged, holding that an employee can prove an employer violated the Iowa Civil Rights Act by showing that a discriminatory or retaliatory motive was a motivating factor or played a part in the employer’s action taken against the employee. Discrimination does not need to be the only reason for the employer’s action for it to violate the ICRA, it just needs to be one of the reasons. This reasoning has always made perfect sense to me because I think it is pretty clear that the legislature intended to prohibit racism, sexism, retaliation, etc. in its entirety and did not intend to allow employers to be just a little racist or a little sexist.
The Court also eliminated the application of the federal rules for proving that an employer discriminated against an employee, which were often confusing for juries . . . and judges and attorneys. Finally, the Court announced that employers are entitled to a “same decision” defense. This means that if an employee proves that discrimination or retaliation was a motivating factor or played a part in the employer’s decision, the employer is liable under the ICRA unless the employer proves that it would have made the same decision even without the discriminatory or retaliatory motive.
As an employment discrimination lawyer, I am looking forward to advocating for my clients under these clearer standards.