Timothy Couch v. American Bottling Company, 955 F.3d 1106

Timothy Couch worked at Dr. Pepper for 17 years and was promoted to plant operations manager in 2015.
New management (Ken Verhulst interim, then Roger Marin permanently) instituted different expectations; supervisors rated Couch as resistant to coaching and not meeting new management expectations.
After a meeting about an internal investigation involving Couch’s wife (a Hispanic employee), Couch interpreted Marin’s comment as a threat and filed discrimination charges with the EEOC and Iowa Civil Rights Commission.
Weeks later Marin gave Couch his first-ever negative interim performance review (2/5); Couch reacted angrily, was suspended, and then fired.
Couch sued for retaliation under Title VII and the Iowa Civil Rights Act; the district court granted summary judgment for Dr. Pepper, and the Eighth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Dr. Pepper retaliated by disciplining and firing Couch after he filed charges	Couch: temporal proximity and Marin’s conduct show retaliation; the timing of review, suspension, and firing was suspicious	Dr. Pepper: legitimate, nondiscriminatory reasons—poor performance, insubordination, and refusal to participate in review; HR involvement was proper	Affirmed for Dr. Pepper: Couch failed to show pretext; timing alone and post-meeting HR reports insufficient to create a jury issue
Whether Iowa law (Hawkins/Hedlund) displaces McDonnell Douglas at summary judgment for indirect-evidence retaliation claims	Couch: Hawkins’ motivating-factor standard undermines McDonnell Douglas and eases plaintiff’s burden at summary judgment	Dr. Pepper: Iowa precedent preserves McDonnell Douglas at summary judgment for indirect-evidence cases; plaintiff must show retaliation was the determinative reason	Affirmed: Iowa cases do not eliminate McDonnell Douglas at summary judgment for indirect-evidence claims; Couch still had to prove retaliatory motive was the real/determinative reason and did not do so

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (established burden-shifting framework for discrimination/retaliation cases)
Hawkins v. Grinnell Reg'l Med. Ctr., 929 N.W.2d 261 (Iowa 2019) (adopted motivating-factor standard for mixed-motive retaliation claims)
Hedlund v. State, 930 N.W.2d 707 (Iowa 2019) (clarified that motivating-factor standard does not displace McDonnell Douglas at summary judgment for indirect-evidence cases)
Van Horn v. Best Buy Stores, L.P., 526 F.3d 1144 (8th Cir. 2008) (applies Title VII framework to Iowa retaliation claims)
Torgerson v. City of Rochester, 643 F.3d 1031 (8th Cir. 2011) (explains plaintiff’s burden to show pretext under McDonnell Douglas)
Donathan v. Oakley Grain, Inc., 861 F.3d 735 (8th Cir. 2017) (timing less probative when plaintiff could anticipate adverse action)
Lindeman v. St. Luke's Hosp. of Kan. City, 899 F.3d 603 (8th Cir. 2018) (new supervisor’s different expectations can explain adverse review)
EEOC v. Kohler Co., 335 F.3d 766 (8th Cir. 2003) (timing alone generally insufficient to prove pretext)
Price Waterhouse v. Hopkins, 490 U.S. 228 (U.S. 1989) (discusses motivating-factor framework in mixed-motive cases)
Deboom v. Raining Rose, Inc., 772 N.W.2d 1 (Iowa 2009) (Iowa precedent on causation and pretext)