Lockhart v. Cedar Rapids Community School DistrictLockhart v. Cedar Rapids Community School District
This case comes to us on a certified question from the United States District Court for the Northern District of Iowa:
DoesIowa Code § 20.7(3) negate the presumption of at-will employment for all public employees covered under this provision of the Iowa Public Employment Relations Act?
I. Background Facts and Proceedings.
Plaintiff, Robert L. Lockhart, was an employee of the defendant, Cedar Rapids Community School District, until his termination in 1996. This lawsuit involves Lockhart’s claims against the school district arising out of his termination. The factual background and procedural history of this case are detailed in the federal district court’s opinion certifying the above question to this court.
See Lockhart v. Cedar Rapids Community Sch. Dist.,
II. Employment Status of Public Employees Under the Common Law.
Before we begin our analysis of
These characterizations of the doctrine do not, however, reflect the current formulation of an employer’s rights vis-a-vis an at-will employee. In
Springer v. Weeks & Leo Co.,
Since our
Springer
decision, we have labeled this remedy an “exception” to the employment-at-will doctrine.
E.g., Anderson,
III.The Positions of the Parties.
Lockhart claims
The school district argues
IV.
Interpretation of
A.
Principles of statutory interpretation.
Our goal in interpreting a statute is to give effect to the intent of the legislature.
See State v. Kidd,
B.
Common usage of words.
Because the parties disagree on the meaning of the term “proper cause,” we focus on that language in the statute. In construing this phrase, we follow the statutory rule that “[wjords and phrases shall be construed according to the context and the approved usage of the language.”
The word “cause” is defined as “a reason or motive for an action or condition.” Webster’s Third New International Dictionary 356 (unabr. ed.1993). The dictionary definition of the word “proper” is less precise: “sanctioned as according with equity, justice, ethics, or rationale <to administer ~ punishment to the perpetrators of these crimes— F.D. Roosevelt> <an adverse wind had so delayed him that his cargo brought but half its ~ price —Amy Lowell>.” Id. at 1817. The nuances of the term “proper” are illustrated by the diverse words having a similar meaning. In Roget’s International Thesaurus, the word “proper” is included in an entry under the category “justice”:
just, fair, square, fair and square; equitable, balanced, level <nonformal>, even, evenhanded; right, rightful; justifiable, justified, warranted, warrantable, defensible; due ..., deserved, merited; meet, meet and right, right and proper, fit, proper, good, as it should or ought to be; lawful, legal....
Roget’s International Thesaurus 456 (Robert L. Chapman ed., 5th ed.1992) (emphasis added). Both of the synonyms for “proper” advanced by the parties — just and lawful — • are included in this entry.
We conclude the precise meaning of the term “proper cause” is not clear from an examination of the common usage of this term. Consequently, we turn to an examination of the context in which the phrase is found.
See
We are prompted to two observations based on the context in which the disputed language is found. First, the language is found in a chapter dealing primarily with collective bargaining as opposed to personnel administration. Section 20.1 states: “The general assembly declares that it is the public policy of the state to promote harmonious and co-operative relationships between government and its employees by permitting public employees to organize and bargain collectively_” (Emphasis added.) In contrast, section 19A.2A, found in the chapter creating the state department of personnel, states: “The general purpose of this chapter is to establish for the state of Iowa a system of personnel administration based on merit principles and scientific methods to govern the ... removal and discipline of its civil employees_” (Emphasis added.) There is no statement of purpose in chapter 20 that supports an interpretation that chapter 20 has even a remotely similar purpose to chapter 19A.
The second observation we make is that the disputed language is found in a section dealing with
employers’
rights, not in the following section, section 20.8, setting forth public
employees’
rights. The interpretation of
D.
Holding.
In examining the context in which the “proper cause” language appears, we conclude the legislature did not intend to establish a just-cause limitation on the right of a public employer to discharge an employee. The legislature’s intent in
Such a restatement of the common law is not meaningless, as suggested by Lockhart. “The only powers of a school district are those expressly granted or necessarily implied in governing statutes.”
Northeast Community Educ. Ass’n v. Northeast Community Sch. Dist.,
It is true that the common law statement of employment at will allows the termination of an employee for no reason at all, a concept not expressed in section 20.7(3). Nevertheless, the legislature’s statement of the employment-at-will doctrine in section 20.7(3) is not a substantial deviation from the common law by virtue of this omission because, as a practical matter, there is always a cause for an employee’s termination- — some motivation or reason prompting the employer to discharge the employee. The traditional statement that an employer could terminate an employee for no reason at all merely emphasized the fact that, no matter what the reason for termination, the - discharge of an employee at will was not actionable. This concept, as modified by our cases limiting nonliability to terminations for any reason not contrary to public policy, is clearly embodied in section 20.7(3).
Because the common meanings of the words used in section 20.7(3) and the context
We hold section 20.7(3) does not change the common law presumption that public employees are employed at will. 2 Therefore, we answer the certified question “no.”
CERTIFIED QUESTION ANSWERED,
Notes
. There is no all-encompassing definition of "just cause.”
See Briggs,
. Lockhart relies on our decisions in
Norton v. Adair County,