Terri Aleta Rivera v. Woodward Resource Center and State of Iowa
865 N.W.2d 887
| Iowa | 2015Background
- Rivera, a probationary residential treatment worker at Woodward Resource Center (WRC), was terminated after accruing three unscheduled absences; she sued for wrongful discharge alleging retaliation for reporting suspected patient abuse.
- Rivera claimed her abuse reports were the determinative factor tipping WRC to fire her; WRC maintained termination followed longstanding practice of firing probationary employees after three unscheduled absences and disputed the timing/merits of Rivera’s reports.
- At trial the district court gave Instruction No. 15, defining "determining factor" ("tips the scales decisively") but adding a sentence that the reports were not determinative if WRC had an "overriding business reason."
- Rivera objected that the "overriding business reason" language shifted the burden and created an improper exception; the district court overruled and the jury returned a verdict for WRC.
- Rivera moved for a new trial; denied. On appeal she argued the instruction was legally erroneous/confusing and (partly) preserved the objection; she also advanced an unpreserved "same-decision" challenge.
- The Iowa Supreme Court reviewed whether lack of a legitimate business justification is a plaintiff element, whether Instruction No. 15 was erroneous or confusing, and whether any error was prejudicial; it affirmed the judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether lack of an "overriding business justification" is an element plaintiff must prove in wrongful-discharge-in-violation-of-public-policy claims | Rivera: Not an element; Iowa precedent uses a heightened "determining factor" causation standard, so adding an overriding-business-justification element improperly burdens the plaintiff | WRC: Some Iowa cases have referenced such an element; instruction was correct or at least not misleading | Held: Lack of legitimate business justification is NOT a required element; causation remains a "determining factor" standard and legitimate business reasons are relevant but not a separate element |
| Whether Instruction No. 15’s "overriding business reason" language improperly shifted burden or confused the jury | Rivera: The fourth sentence permitted jurors to "override" a determinative unlawful motive with a business reason, conflicting with the "tips the scales" standard and risking burden-shifting | WRC: Instruction read as a whole correctly stated the law; the sentence simply restated that legitimate reasons can prevent a finding that protected conduct was the determinative factor | Held: Court found the instruction could be harmonized and was not misleading when read as a whole; no reversible error on this preserved claim |
| Whether the third sentence of Instruction No. 15 advanced an impermissible "same-decision" theory (preservation issue) | Rivera: The instruction allowed a same-decision defense (if employer would have decided the same absent the protected conduct) and that theory is improper here | WRC: N/A (issue not preserved) | Held: Same-decision challenge was not preserved for appellate review; Court declined to address it on the merits |
| Whether any instructional error was prejudicial requiring a new trial | Rivera: Error undermined the core causation instruction and likely confused jurors; prejudicial given contested facts | WRC: Any error was harmless; case was one of credibility, and evidence supported WRC’s verdict | Held: Any potential error was not prejudicial given the instructions as a whole; judgment affirmed (but two justices dissented in part, arguing the error required a new trial) |
Key Cases Cited
- Smith v. Smithway Motor Xpress, Inc., 464 N.W.2d 682 (Iowa 1990) (articulates the "determining factor" causation standard: "tips the scales decisively")
- Teachout v. Forest City Cmty. Sch. Dist., 584 N.W.2d 296 (Iowa 1998) (reaffirms high "determining factor" causation standard in public-policy discharge claims)
- Fitzgerald v. Salsbury Chem., Inc., 613 N.W.2d 275 (Iowa 2000) (discusses causation and includes a footnote noting a four-element formulation mentioning lack of overriding business justification)
- Phipps v. IASD Health Servs. Corp., 558 N.W.2d 198 (Iowa 1997) (legitimate employer reasons are relevant evidence in assessing whether protected conduct was determinative)
- DeBoom v. Raining Rose, Inc., 772 N.W.2d 1 (Iowa 2009) (instructions using conflicting causation standards require reversal)
- Hagen v. Siouxland Obstetrics & Gynecology, P.C., 964 F.Supp.2d 951 (N.D. Iowa 2013) (federal district court canvasses Iowa law and questions whether lack of overriding business justification is a separate element)