Erin Dindinger, Lisa Loring, and Elizabeth Freund v. Allsteel, Inc. and Scott Mills, 860 N.W.2d 557

Plaintiffs (Dindinger, Loring, Freund) sued Allsteel and a supervisor alleging they were paid less than male employees for equal work and asserted claims under the Federal Equal Pay Act and the Iowa Civil Rights Act (ICRA).
In 2009 the Iowa Legislature added Iowa Code § 216.6A (a new, intent‑neutral wage‑discrimination cause of action) and an enhanced remedial provision in § 216.15(9)(a)(9) (double or treble wage differential damages).
Plaintiffs amended to add § 216.6A claims but some discriminatory pay allegedly occurred before § 216.6A’s July 1, 2009 effective date.
The federal district court certified two questions to the Iowa Supreme Court about (1) whether § 216.6A and its enhanced remedy apply retroactively, and (2) if not, whether plaintiffs can recover under the preexisting § 216.6 and for what period.
The Iowa Supreme Court held: (1) § 216.6A and the enhanced remedy are prospective only (not retroactive); (2) plaintiffs may pursue § 216.6 wage‑discrimination claims, but recoverable lost wages are limited to discriminatory payments made within 300 days before filing a complaint with the Iowa Civil Rights Commission.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Iowa Code § 216.6A and the enhanced remedy § 216.15(9)(a)(9) apply retroactively to pre‑effective‑date pay discrimination	§ 216.6A is remedial or procedural and should apply retroactively to permit recovery for pre‑2009 discrimination	§ 216.6A creates new substantive liability and, absent express retroactivity, applies only prospectively	Prospective only; § 216.6A creates a new strict‑liability cause of action and thus is substantive and not retroactive
If § 216.6A is prospective only, whether plaintiffs can recover under pre‑existing § 216.6 and the temporal scope of recoverable damages	Plaintiffs may recover lost wages for the entire period of discriminatory pay so long as at least one paycheck fell within the 300‑day limitations period	Defendants contend the pay‑setting decision triggered the limitations period and earlier pay‑setting is time‑barred	Plaintiffs may proceed under § 216.6; each discriminatory paycheck is a discrete act with its own 300‑day limitations period, so recovery is limited to wages unpaid/underpaid within 300 days before filing with the ICRC

Hy‑Vee Food Stores, Inc. v. Iowa Civil Rights Comm’n, 453 N.W.2d 512 (Iowa 1990) (discussed continuing‑violation doctrine and types of continuing violations)
Farmland Foods, Inc. v. Dubuque Human Rights Comm’n, 672 N.W.2d 733 (Iowa 2003) (adopted Morgan’s discrete‑acts approach for ICRA claims)
Nat’l R.R. Passenger Corp. v. Morgan, 536 U.S. 101 (U.S. 2002) (each discrete discriminatory act starts a new limitations period; continuing violation limited to hostile‑work‑environment type claims)
Ledbetter v. Goodyear Tire & Rubber Co., 550 U.S. 618 (U.S. 2007) (majority tied limitations to pay‑setting decision; dissent argued each discriminatory paycheck is actionable)
Bazemore v. Friday, 478 U.S. 385 (U.S. 1986) (each discriminatory paycheck is an actionable wrong)
Dutcher v. Randall Foods, 546 N.W.2d 889 (Iowa 1996) (recognized pay disparity claim under ICRA)
Madison v. IBP, Inc., 330 F.3d 1051 (8th Cir. 2003) (addressed continuing violation under Iowa law post‑Morgan)
Alexander v. Seton Hall Univ., 8 A.3d 198 (N.J. 2010) (each discriminatory paycheck is a separable actionable wrong subject to the statute of limitations)
Zuurbier v. Medstar Health, Inc., 895 A.2d 905 (D.C. 2006) (treated each discriminatory paycheck as a discrete act with separate limitations implications)