Nolan Deeds v. City of Cedar Rapids, St. Luke's Work Well Solutions, St. Luke's Healthcare, and Iowa Health System D/B/A Unitypoint Health
16-1779
| Iowa Ct. App. | Oct 11, 2017Background
- Nolan Deeds, diagnosed with relapsing-remitting Multiple Sclerosis (asymptomatic at time of events), applied and received a conditional firefighter offer from the City of Cedar Rapids in July 2013 contingent on a medical screening.
- The City contracted UnityPoint (St. Luke’s entities) to perform medical exams; Dr. Jeffrey Westpheling reviewed Deeds’s records, found recent MS symptoms, consulted NFPA guidelines, and marked Deeds "disqualified." He did not state a specific reason in the report.
- The City rescinded the employment offer after receiving the "Confidential Report." Deeds filed an administrative complaint and then sued under the Iowa Civil Rights Act (ICRA) alleging disability discrimination by the City and aiding-and-abetting by UnityPoint.
- District court granted summary judgment for both defendants; Deeds appealed only the discrimination and aiding-and-abetting claims.
- The majority affirmed summary judgment: it held Deeds failed to show the City rescinded the offer because of his disability (no evidence the City knew Dr. Westpheling used NFPA or knew of Deeds’s MS), and because plaintiff failed to prove the underlying discriminatory act, the aiding-and-abetting claim against UnityPoint failed.
- Concurring/dissenting opinion (Vaitheswaran, P.J.) agreed with the UnityPoint ruling but would have found a genuine issue of material fact as to whether the City’s action was motivated by disability and remanded as to the City.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the City rescind hire because of disability in violation of ICRA? | Deeds: City rescinded offer because of his MS; Dr. Westpheling’s use of NFPA guidelines shows discriminatory motive. | City: Rescission was based on an independent medical determination that Deeds was not medically qualified; City relied on UnityPoint’s professional judgment and had no knowledge of NFPA use or of MS diagnosis. | Held for City — no genuine issue that disability motivated rescission; plaintiff failed to show City knew of/used NFPA or acted with discriminatory motive. |
| Did UnityPoint aid and abet discrimination under ICRA? | Deeds: UnityPoint (via its doctor) aided/abetted by providing the disqualifying medical report. | UnityPoint: Role was advisory; no underlying discriminatory act by City to which UnityPoint could have aided/abetted. | Held for UnityPoint — aiding-and-abetting claim fails because plaintiff did not establish the City committed a discriminatory practice. |
Key Cases Cited
- Casey’s Gen. Stores, Inc. v. Blackford, 661 N.W.2d 515 (Iowa 2003) (elements of prima facie disability discrimination under ICRA)
- Sahai v. Davies, 557 N.W.2d 898 (Iowa 1997) (third-party physician’s advisory role in hiring decision limits discrimination liability)
- Veatch v. City of Waverly, 858 N.W.2d 1 (Iowa 2015) (appellate court may affirm on alternative grounds urged below)
- Goodpaster v. Schwan’s Home Serv., Inc., 849 N.W.2d 1 (Iowa 2014) (summary-judgment standards for discrimination cases and assessing genuine issues of material fact)
- Barker v. Capotosto, 875 N.W.2d 157 (Iowa 2016) (standard of review for summary judgment)
- Pellegrini v. Sovereign Hotels, Inc., 760 F. Supp. 2d 344 (N.D.N.Y. 2011) (aider-and-abettor liability requires an underlying unlawful practice by the principal)