Juanette Plato v. Anderson Erickson Dairy Company, 17-0222

Plato worked at Anderson Erickson Dairy (AE) as an HR administrative assistant starting October 2013 and applied for a new HR representative position in Dec. 2013; she was interviewed but AE hired a man, Chad Van Hauen.
AE HR director Abbott told Plato during her interview there was no reason she could not do the job; Abbott later told his supervisor Henson he thought the plant environment was "not a good environment for a female" because it was "pretty rough."
Plato continued as HR assistant; Henson (her original supervisor) praised her work, but after Henson left Abbott made Van Hauen interim HR manager and Van Hauen reported performance and attitude concerns about Plato.
Plato filed an Iowa Civil Rights Commission complaint alleging race and gender discrimination on Oct. 23, 2014; AE terminated her employment Oct. 24, 2014; she later sued for sex discrimination under the Iowa Civil Rights Act.
The district court granted AE summary judgment, finding no genuine issue of material fact on qualification, discriminatory motive, or pretext for either the failure-to-hire or termination claims.
The Court of Appeals reversed and remanded, holding that viewed in Plato’s favor the record contains direct and circumstantial evidence creating genuine fact disputes on both failure-to-hire and termination claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Failure to hire for HR representative	Abbott made sex-biased remarks and preferred male candidate despite comparable qualifications; Abbott’s statement shows discriminatory motive	Plato lacked the preferred HR/union experience; hiring decision based on legitimate, nondiscriminatory criteria	Reversed: factual dispute exists on qualification and Abbott’s remark is direct evidence raising an inference of discriminatory motive, so summary judgment improper
Termination from HR assistant position	Termination was motivated by sex because Abbott (ultimate decisionmaker) held biased beliefs and Van Hauen’s performance complaints are disputed	Termination was based on legitimate concerns about professionalism, trustworthiness, attitude, and not performing assigned work	Reversed: record contains conflicting evidence and inferences about motive and pretext; credibility issues preclude summary judgment

Homan v. Brandstad, 887 N.W.2d 153 (Iowa 2016) (standards for appellate review of summary judgment)
Pecenka v. Fareway Stores, Inc., 672 N.W.2d 800 (Iowa 2003) (framework for disparate-treatment claims)
Hamer v. Iowa Civil Rights Comm’n, 472 N.W.2d 259 (Iowa 1991) (prima facie case and burden-shifting in discrimination claims)
Vaughan v. Must, Inc., 542 N.W.2d 533 (Iowa 1996) (direct-evidence route and Price Waterhouse burden allocation)
Price Waterhouse v. Hopkins, 490 U.S. 228 (U.S. 1989) (when plaintiff shows discriminatory attitude by decisionmaker, employer must prove same-decision defense)
Walker Shoe Store v. Howard's Hobby Shop, 327 N.W.2d 725 (Iowa 1982) (summary judgment inappropriate when reasonable minds could draw different inferences)