Harvey v. Care Initiatives, Inc.

Summary

The Iowa Supreme Court held that an independent contractor has no tort cause of action for retaliatory termination under Iowa public policy based on reporting alleged violations at a health care facility. The court concluded that Iowa Code section 135C.46 protects residents and employees, but not independent contractors, and affirmed summary judgment for Care Initiatives, Inc.

Holdings

1. An independent contractor has no Iowa tort action for retaliatory termination of a contract under the allegations presented.
2. The public policy expressed in Iowa Code section 135C.46 does not protect independent contractors because the statute limits its anti-retaliation protection to a resident or an employee of the facility.
3. The district court properly granted summary judgment to Care Initiatives.

Questions Presented

1. Whether Iowa's tort of wrongful discharge in violation of public policy extends to independent contractors.
2. Whether Iowa Code sections 135C.37 and 135C.46 establish a clear public policy protecting an independent contractor from retaliatory termination for reporting an alleged violation at a health-care facility.
3. Whether summary judgment was properly granted to Care Initiatives.

Disposition

affirmed