Appeal from the Iowa District Court for Warren County, Gregory A. Hulse, Judge.
Plaintiffs appeal a ruling of the district court granting defendants' motion to strike plaintiffs' claim for punitive damages.
Jill M. Zwagerman and Bryan P. O'Neill of Newkirk Law Firm, P.L.C., Des Moines, for appellants.
Frank B. Harty, Mary E. Funk, Debra L. Hulett of Nyemaster Goode, P.C., Des Moines, and Frances M. Haas of Nyemaster Goode, P.C., Cedar Rapids, for appellees.
Thomas J. Duff of Duff Law Firm, P.L.C., Des Moines, Kodi A. Brotherson and Katie A. Ervin Carlson of Babich Goldman, P.C., Des Moines, and Emily E. McCarty of Fiedler & Timmer, P.L.L.C., Urbandale, for amicus curiae Iowa Association of Justice.
James P. Craig, Brenda K. Wallrichs, and Megan R. Dimitt of Lederer Weston Craig, P.L.C., Cedar Rapids, for amicus curiae Iowa Defense Counsel Association.
Russell L. Samson and Sara R. Laughlin of Dickinson, Mackaman, Tyler & Hagen, P.C., Des Moines, for amicus curiae Iowa Association of Business and Industry.
CADY, Chief Justice.
In this appeal, we must decide whether the Iowa Civil Rights Act (ICRA) permits a district court to award punitive damages. The district court held an award of punitive damages is not permitted under the ICRA. On our review, we affirm the decision of the district court and remand for further proceedings.
I. Background Facts and Proceedings.
Tammie Ackelson, Robin Drake, and Heather Miller were employees of Manley Toy Direct and Toy Network, both limited liability corporations located in Indianola, Iowa, with parent companies in Hong Kong. The businesses purchase and sell toys and other merchandise.
In 2010, the three employees initiated lawsuits against the businesses, collectively referred to as Manley Toy, and certain individuals associated with the businesses. The petitions alleged employment practice claims based on a violation of the ICRA. The claims alleged a supervisor named Tim Downey and a coworker named Steffen Hampton repeatedly made vulgar and harassing comments to the women, including demeaning name-calling, and sexually explicit and offensive discussions about Downey's sexual relationships. The lawsuits articulated claims for sexual harassment, sex discrimination, and retaliation under the ICRA and demanded punitive damages. No other claims were alleged.
Manley Toy moved to strike the claim for punitive damages. The district court granted Manley Toy's motion. It reasoned that the court could only grant relief that the civil rights commission was authorized to grant, and punitive damages are not available under the ICRA.
The plaintiffs sought, and we granted, interlocutory appeal. They ask us to review our prior decisions holding that punitive damages are not available for claims under the ICRA and to interpret the ICRA to permit courts to award punitive damages.
II. Standard of Review.
We review a decision by the district court on a motion to strike for correction of legal errors. See Iowa R. App. P. 6.907. Similarly, we review an interpretation of a statute for correction of legal errors. Rolfe State Bank v. Gunderson, 794 N.W.2d 561, 564 (Iowa 2011).
A. ICRA Framework.
The ICRA prohibits unfair and discriminatory employment practices against a person "because of" the person's membership in a protected class and provides for a claim for relief. Iowa Code §§ 216.6(1)(a), .15 (Supp. 2009). Persons who seek to assert their rights under the ICRA, however, must follow the statutory processes to obtain relief. See id. §§ 216.15–.16. This procedure begins by filing a ...