Lucas Woods v. Charles Gabus Ford, Inc.
19-0002
| Iowa | Jun 25, 2021Background
- Lucas Woods, a lube technician at Charles Gabus Ford (CGF), was randomly drug-tested on Aug. 9, 2017; his first urine sample was rejected as insufficient/possibly altered and a second sample tested positive for methamphetamine.
- Quest Diagnostics confirmed the positive result; the medical reviewer’s attempts to contact Woods failed because they called the wrong phone number, and the result was relayed to CGF’s HR director, Kelsey Gabus McBride.
- CGF terminated Woods and sent him a certified-mail notice (not sent return receipt requested) informing him of the positive result, his right to a confirmatory retest at his cost, and that CGF would reimburse him if the retest was negative; the letter did not state the specific cost of the retest.
- Woods sued under Iowa Code § 730.5(15), claiming CGF failed to comply with statutory notice requirements (failure to include retest cost; failure to send return receipt requested) and later asserted the HR director was not properly trained.
- The district court found CGF substantially complied and dismissed the petition; the court of appeals reversed on the cost-of-retest ground but upheld the mailing method; CGF sought further review.
- The Iowa Supreme Court affirmed in part, reversed in part (holding omission of retest cost fatal to substantial compliance), and remanded for determination of appropriate equitable relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Preservation/training of HR administrator under §730.5(9)(h) | Woods: HR director was not properly trained, making process invalid | CGF: Issue was raised only after trial; CGF had no opportunity to present evidence | Not preserved; court declined to decide training sufficiency |
| Inclusion of retest cost in notice (§730.5(7)(j)(1)) | Woods: Letter omitted the fee, so employee lacked meaningful opportunity to decide | CGF: Letter otherwise informed Woods of right to retest and deadline; omission harmless | Failure to include the cost defeats substantial compliance; reversal on this issue |
| Method of mailing—return receipt requested? (§730.5(7)(j)(1)) | Woods: Letter not sent return receipt requested, so not compliant | CGF: Sent by certified mail (no return receipt); employee received notice | Certified mail without return receipt requested substantially complied |
| Remedy for statutory violation | Woods: Aggrieved and seeks monetary relief (back pay, front pay) | CGF: No substantive harm shown; district court awarded no relief | Remanded to district court to determine appropriate equitable relief (back pay/front pay) on existing record |
Key Cases Cited
- Sims v. NCI Holding Corp., 759 N.W.2d 333 (Iowa 2009) (adopting substantial-compliance standard for §730.5 notice and requiring a meaningful opportunity to pursue a confirmatory test)
- Harrison v. Emp. Appeal Bd., 659 N.W.2d 581 (Iowa 2003) (describing §730.5 protections and formal notice purpose)
- Tow v. Truck Country of Iowa, Inc., 695 N.W.2d 36 (Iowa 2005) (employee aggrieved by statutory violation may receive back pay even if retest not taken)
- UE Loc. 893/IUP v. State, 928 N.W.2d 51 (Iowa 2019) (appellate preservation: issues must be raised and decided below to be reviewed)
- Meier v. Senecaut, 641 N.W.2d 532 (Iowa 2002) (preservation doctrine; district court must be given opportunity to decide issues)
- In re Est. of Johnson, 739 N.W.2d 493 (Iowa 2007) (standard of review in bench trials: de novo for legal conclusions; deference to factual findings)
- Sellers v. Mineta, 358 F.3d 1058 (8th Cir. 2004) (post-termination misconduct may render reinstatement or front pay inappropriate)