Todd P. Halbur v. Stephen Larson, Administrator of the Alcoholic Beverages Division, in his Official Capacity, 14 N.W.3d 363

Todd Halbur served as comptroller for the Iowa Alcoholic Beverages Division (ABD) and raised concerns about ABD’s pricing practices and contract procurement, both of which he believed violated Iowa law.
Halbur reported these concerns directly to his supervisor, ABD Administrator Stephen Larson, and refused to authorize additional payments under a contract he believed was unlawfully procured.
Shortly after these actions, Halbur’s reporting structure was changed and he was terminated without explanation.
Halbur filed a suit alleging wrongful termination under the Iowa whistleblower statute (Iowa Code § 70A.28) and under Iowa common law (public policy exception to at-will employment).
The district court let the statutory whistleblower claim proceed to trial but dismissed the common law claim as precluded by the statute; Halbur won a jury verdict, which was capped by statute.
On appeal, Larson challenged whether Halbur’s internal complaints to his supervisor constituted protected disclosures; Halbur cross-appealed on the dismissal of his public policy claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether reporting violations to a supervisor is a protected disclosure under Iowa Code § 70A.28	Halbur: Reporting to any public official, even a supervisor, is protected whistleblowing	Larson: Disclosure to a supervisor about the supervisor's own conduct is not a statutory "disclosure"	Court: Did not reach merits; ruled issue was not preserved for appeal by Larson
Exclusivity of statutory whistleblower remedy vs. common law wrongful discharge claim	Halbur: Should be able to bring both statutory and common law claims	Larson: Statutory remedy is exclusive where public policy is embodied in statute	Court: Statutory remedy under § 70A.28 is exclusive; common law claim was properly dismissed
Whether Halbur's refusal to approve potentially unlawful payments was a distinct ground for public policy claim	Halbur: Refusal to commit an illegal act should support a common law claim	Larson: Any such claim is subsumed under the whistleblower statute	Court: Refusal intertwined with whistleblowing; statutory remedy is exclusive and covers underlying conduct
Preservation of error for appeal by Larson on whether internal supervisor disclosures are protected	Halbur: Larson did not properly preserve error for appeal	Larson: Pretrial motions and judicial statements preserved issue	Court: Error not preserved—denial of a motion to dismiss must be renewed at trial to preserve issue for appeal

Jones v. Univ. of Iowa, 836 N.W.2d 127 (Iowa 2013) (outlining limited public policy exception to at-will employment)
Fitzgerald v. Salsbury Chem., Inc., 613 N.W.2d 275 (Iowa 2000) (explaining at-will employment and wrongful discharge public policy exception)
Ferguson v. Exide Technologies, Inc., 936 N.W.2d 429 (Iowa 2019) (holding comprehensive statutory civil remedy precludes common law wrongful discharge claim)
Dorshkind v. Oak Park Place of Dubuque II, L.L.C., 835 N.W.2d 293 (Iowa 2013) (describing narrow scope of public policy discharge claims)
Ballalatak v. All Iowa Agric. Ass’n, 781 N.W.2d 272 (Iowa 2010) (reaffirming narrow exception for public policy discharge claims)
Lloyd v. Drake Univ., 686 N.W.2d 225 (Iowa 2004) (caution in expanding implied causes of action for wrongful discharge)