Appeal from the Iowa District Court for Chickasaw County, Richard D. Stochl, Judge.
Deanna Eastman appeals from the district court's grant of summary judgment to her employer in this wrongful discharge claim.
Aaron R. Murphy of Walk & Murphy, P.L.C., Osage, for appellant.
Kevin J. Visser and Lisa A. Stephenson of Simmons Perrine Moyer & Bergman, P.L.C., Cedar Rapids, for appellee.
Considered by Doyle, P.J., and Danilson and Mullins, JJ.
Deanna Eastman appeals from the district court's grant of summary judgment to her employer, Homeland Energy Solutions, LLC, in this wrongful discharge claim. Eastman's employment was terminated for insubordination. She filed a petition contending her act of calling the employer's auditor with claims of improper handling of election ballots during a board of directors' election constitutes whistleblowing, which was a factor in her firing.
"Generally, an employer may fire an at-will employee at any time." Ballalatak v. All Iowa Agric. Ass'n, 781 N.W.2d 272, 275 (Iowa 2010). A claim of wrongful discharge is "narrow exception" to Iowa's general at-will rule. Id. Our courts have recognized "four categories of activities protected by public policy in Iowa law: '(1) exercising a statutory right or privilege, (2) refusing to commit an unlawful act, (3) performing a statutory obligation, and (4) reporting a statutory violation.'" Id. (citation omitted). The district court entered summary judgment for the employer because Eastman failed to identify a clearly defined public policy that was violated by her termination. As the district court concluded:
Deanna has not identified any clearly defined public policy which was violated by her termination. There is no statute that protects her rights of insubordination. There is nothing in the constitution that would prohibit her termination under these circumstances. There is no administrative rule or prior court decision that protects her from termination. Deanna lodged an internal complaint in April of 2010 alleging improper handling of an election in which her husband lost. She was terminated nearly a year later after disobeying instructions and being insubordinate to the company president. Nothing about her termination violates current, well established public policy. She admits so in her own pleadings. Because she cannot identify any known policy that has been violated, she has no claim for wrongful discharge. She was lawfully terminated as an at-will employee.
On appeal, Eastman argues that "this case presents an opportunity for the court to extend and clarify what constitutes public policy." (Emphasis added.) We decline the invitation. Her argument on appeal demonstrates that no "well-recognized and defined public policy of the state" is at issue. See Ballaltak, 781 N.W.2d at 277 (rejecting wrongful discharge claim where caselaw suggested "internal whistle-blowing may be protected in certain circumstances" because "all wrongful discharge claims must be based on 'a well-recognized and defined public policy of the state'" (quoting Springer v. Weeks & Leo Co., Inc., 429 N.W.2d 558, 560 (Iowa 1988)).