912 N.W.2d 136
Iowa2018Background
- Jahnke, a U.S. citizen and Deere employee, worked from 2011–2014 as factory manager at Harbin Works in China under a host‑country employment contract; his Deere "home unit" was in Ankeny, Iowa but had minimal ongoing involvement.
- A China‑based Deere compliance investigation found Jahnke had undeclared sexual relationships with two Chinese employees within his span of control; the China Compliance Committee recommended removal and repatriation.
- Deere’s global compliance office in Moline, Illinois, approved the recommendation; Deere managers Czarnecki and Haas (who have Iowa residences) were sent to China to inform Jahnke and later assisted in U.S. reassignment.
- Jahnke was repatriated in July 2014 and reassigned to a lower‑grade position in Waterloo, Iowa; he filed an ICRC complaint and then suit under the Iowa Civil Rights Act (ICRA) alleging age, sex, and national‑origin discrimination.
- Deere moved for summary judgment arguing the ICRA lacks extraterritorial reach and the alleged discriminatory acts occurred outside Iowa; the district court denied the motion and Deere obtained interlocutory review.
- The Iowa Supreme Court reversed, holding the ICRA does not apply extraterritorially and, on these facts, the employment relationship and the discrete adverse actions were not sufficiently located in Iowa to invoke the ICRA.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ICRA applies extraterritorially | Jahnke: ICRA should apply because he is an Iowan and rights/causes arose in Iowa; contacts with Iowa suffice | Deere: ICRA has no extraterritorial reach; alleged acts occurred outside Iowa | ICRA does not apply extraterritorially absent clear legislative intent; none here |
| Whether ICRA applies given parties’ contacts with Iowa | Jahnke: contacts (home unit, managers’ Iowa ties) bring the case within ICRA | Deere: contacts are tangential; core employment relationship and decisions were in China (and Moline, IL) | Mere contacts/domicile insufficient; core employment relationship and adverse acts were not in Iowa |
| Whether Czarnecki and Haas made the disciplinary decisions from Iowa | Jahnke: those managers (Iowa residents) were responsible and acted from Iowa | Deere: managers only informed Jahnke; decisions originated with China and Moline compliance committees | Record shows China and Moline committees decided discipline; Czarnecki and Haas merely communicated the decision |
| Proper forum/venue under ICRA for these actions | Jahnke: Polk County (Iowa) appropriate because of home unit and subsequent reassignment | Deere: venue improper—discrete unfair practices occurred outside Iowa; principal business not in Polk County | Venue improper; ICRA venue rules point to location of respondent/practice, not plaintiff’s prior home unit |
Key Cases Cited
- Griffen v. State, 767 N.W.2d 633 (Iowa 2009) (statutes presumed not to have extraterritorial effect absent clear legislative expression)
- State Sur. Co. v. Lensing, 249 N.W.2d 608 (Iowa 1977) (presumption against extraterritoriality and interpretive framework)
- Morrison v. Nat’l Austl. Bank Ltd., 561 U.S. 247 (2010) (federal statute applies domestically unless Congress clearly indicates otherwise)
- E.E.O.C. v. Arabian Am. Oil Co., 499 U.S. 244 (1991) (declining extraterritorial application of employment statute)