Timothy T. Bradshaw, plaintiff-appellant/cross-appellee v. Cedar Rapids Airport Commission, defendant-appellee/cross-appellant.
903 N.W.2d 355
| Iowa Ct. App. | 2017Background
- Bradshaw was Airport Director under a 2012 amended employment agreement that promised 12 months’ severance if the Commission “involuntarily terminated” him for reasons other than specified disqualifying conduct. Paragraph 13 declared the agreement the parties’ full understanding.
- On September 3, 2014 Bradshaw emailed a resignation stating his last day would be November 3, 2014. He had earlier told commissioners he would resign if a requested raise was not approved.
- The Commission responded that a special meeting would accept the resignation and set a pay-through date 30 days later (October 5). On September 5 the Commission adopted a resolution accepting the resignation effective 30 days from the resolution.
- Bradshaw filed for unemployment (later withdrawn), then demanded 12 months’ severance in February 2015; the Commission refused and Bradshaw sued for breach of contract.
- The district court granted summary judgment to the Commission on the severance claim (holding Bradshaw voluntarily resigned) but awarded Bradshaw $13,023.36 for pay from October 5–November 3. Both parties appealed.
- The Iowa Court of Appeals affirmed that Bradshaw was not involuntarily terminated under the contract, reversed the award for the additional month, and remanded with instructions to dismiss Bradshaw’s claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Bradshaw was "involuntarily terminated" under the severance clause | Bradshaw argued he resigned effective Nov. 3, Commission accelerated his final date to Oct. 5 — that acceleration made the separation an involuntary termination entitling him to severance | Commission argued Bradshaw voluntarily resigned and its acceptance (with an earlier effective date) did not convert the separation into an involuntary termination | Court held Bradshaw voluntarily resigned and the Commission did not involuntarily terminate him under the contract; no severance owed |
| Whether Bradshaw was entitled to pay from Oct. 5–Nov. 3 despite the Commission paying through Oct. 5 | Bradshaw argued his notice fixed Nov. 3 as departure date so he was owed pay through then | Commission argued it properly set the effective date (Oct. 5) and paid through that date; no contractual or legal basis for extra pay | Court held district court erred; no legal basis for additional compensation and Bradshaw conceded he was not entitled in reply brief |
Key Cases Cited
- Pillsbury Co. v. Wells Dairy, Inc., 752 N.W.2d 430 (Iowa 2008) (rules on contract interpretation and construction)
- Home Fed. Sav. & Loan Ass’n v. Campney, 357 N.W.2d 613 (Iowa 1984) (interpretation seeks parties’ intent as evidenced by contract language)
- Irving v. Employment Appeal Bd., 883 N.W.2d 179 (Iowa 2016) (discusses involuntary v. voluntary termination in employment contexts)
- Bridgestone/Firestone, Inc. v. Employment Appeal Bd., 570 N.W.2d 85 (Iowa 1997) (unemployment-compensation law is liberally construed for employees)
- Emmet County State Bank v. Reutter, 439 N.W.2d 651 (Iowa 1989) (summary judgment appropriate where only legal consequences of undisputed facts remain)
- Wilson v. Darr, 553 N.W.2d 579 (Iowa 1996) (moving party prevails on summary judgment if opposing party lacks evidence on an outcome-determinative element)
