14 N.W.3d 716
Iowa2024Background
- Silvia Cianzio, a professor at Iowa State University specializing in plant breeding, alleged wage discrimination based on gender after discovering pay disparities through a departmental survey before her retirement.
- Cianzio’s annual pay lagged significantly behind that of male professors in her specialty—by $11,000 to $46,000 per year.
- She reported her findings to university officials, who took no further action.
- After retiring and receiving her last paycheck in December 2020, Cianzio filed an employment discrimination complaint with the Iowa Civil Rights Commission (ICRC) in August 2021, received a right-to-sue letter, and then sued the University.
- The key legal dispute arose after the University moved to dismiss any claims for damages predating the 300-day period before her ICRC complaint.
- The district court limited damages to a two-year period before filing, based on a separate statute of limitations for wage claims, but Cianzio appealed this restriction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Damages period for wage discrimination | Damages available for the full period of discrimination since July 1, 2009, as long as the claim was timely filed | Damages limited to paychecks within 300 days of ICRC complaint; alternatively, limited to two years prior to filing under another wage statute | Statute allows damages for the entire period of discrimination, not limited by 300 days or two years, except prospectively from July 1, 2009 |
Key Cases Cited
- Dindinger v. Allsteel, Inc., 860 N.W.2d 557 (Iowa 2015) (interpreted Iowa wage discrimination statute’s coverage and damages period; highlighted that recovery is permitted for the full period of discrimination as long as some occurred within the limitations period)
- Bob McKiness Excavating & Grading, Inc. v. Morton Bldgs., Inc., 507 N.W.2d 405 (Iowa 1993) (explained distinction between statutes of limitations and damages statutes)
- Randolph v. Aidan, LLC, 6 N.W.3d 304 (Iowa 2024) (reaffirmed that courts must enforce statutes as written, without adding limitations not present in the text)
- State v. Iowa Dist. Ct., 730 N.W.2d 677 (Iowa 2007) (courts cannot read into statutes words not present by legislative choice)