Nolan Deeds v. City of Marion, St. Luke's Work Well Solutions, St. Luke's Healthcare and Iowa Health Systems D/B/A Unitypoint Health
16-1666
| Iowa Ct. App. | Oct 11, 2017Background
- Nolan Deeds, diagnosed with relapsing–remitting MS (asymptomatic at time of events), applied for a firefighter job with the City of Marion and received a conditional offer in Nov. 2013 contingent on a medical exam and background check.
- The City contracted UnityPoint (St. Luke’s entities) to perform medical evaluations; Dr. Ann McKinstry interviewed Deeds but did not perform a physical exam.
- Dr. McKinstry marked Deeds “not medically qualified” on the MFPRSI form after consulting NFPA guidelines (which disqualify applicants with MS symptoms in prior 3 years); she did not explain the basis on the form.
- The City rescinded the offer after reviewing the completed medical form and did not ask UnityPoint or Deeds for further explanation; Chief Jackson testified he did not know the specific reason for the disqualification.
- Deeds sued under the Iowa Civil Rights Act for disability discrimination and alleged UnityPoint aided and abetted; the district court granted summary judgment for both defendants.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the City rescind the job offer because of Deeds’s disability (ICRA discrimination)? | Deeds: rescission was motivated by his MS diagnosis; NFPA-based disqualification shows discriminatory motive. | City: rescinded based on a medical determination that he was not medically qualified; City did not know UnityPoint used NFPA or know of Deeds’s MS. | Court: No genuine issue that City acted because of disability; summary judgment for City affirmed. |
| Was UnityPoint liable for aiding and abetting discrimination under ICRA §216.11(1)? | Deeds: UnityPoint’s medical determination aided City’s discriminatory act. | UnityPoint: role was advisory/medical evaluation only; cannot be liable where employer’s discriminatory act not established. | Court: Because City did not engage in discriminatory practice, aiding-and-abetting claim fails; summary judgment for UnityPoint affirmed. |
| Was UnityPoint’s use of NFPA standards improper and imputed to City? | Deeds: NFPA’s categorical MS exclusion violates ICRA and its use permits inference of discrimination. | Defendants: NFPA reliance was Dr. McKinstry’s independent judgment; City neither required nor knew of NFPA use. | Court: No evidence City instructed or knew UnityPoint used NFPA; cannot impute discriminatory motive to City. |
| Did material facts remain for trial on discriminatory motive? | Deeds: Dr. McKinstry’s unexplained disqualification and NFPA reliance create inference of discriminatory motive. | City/UnityPoint: absence of knowledge and lack of explanation defeats inference; advisory opinion cannot impose liability. | Held: Majority found no genuine issue on motive; dissenter would have found a genuine issue as to the City. |
Key Cases Cited
- Barker v. Capotosto, 875 N.W.2d 157 (Iowa 2016) (summary judgment standard review)
- Nelson v. Lindaman, 867 N.W.2d 1 (Iowa 2015) (summary judgment principles; view facts favoring nonmoving party)
- Homan v. Branstad, 887 N.W.2d 153 (Iowa 2016) (standards for appellate review of summary judgment)
- Walker Shoe Store v. Howard’s Hobby Shop, 327 N.W.2d 725 (Iowa 1982) (reasonable minds may draw different inferences from undisputed facts)
- Casey’s Gen. Stores, Inc. v. Blackford, 661 N.W.2d 515 (Iowa 2003) (elements of disability-discrimination prima facie case)
- Sahai v. Davies, 557 N.W.2d 898 (Iowa 1997) (advisory physician’s role in employer hiring decisions)
- Veatch v. City of Waverly, 858 N.W.2d 1 (Iowa 2015) (appellate court may affirm on alternate grounds urged below)
- Goodpaster v. Schwan’s Home Serv., Inc., 849 N.W.2d 1 (Iowa 2014) (evidence required to show discriminatory motive)