Karen Dorshkind v. Oak Park Place of Dubuque II, L.L.C.

Summary

The Iowa Supreme Court held that an at-will employee’s internal report of forged state-mandated dementia-training documents could support a wrongful-discharge claim under Iowa’s public-policy exception to at-will employment. The court affirmed the compensatory-damages ruling but held punitive damages were unavailable because, at the time of the discharge, Iowa had not recognized a public-policy exception based on violations of administrative rules. The court remanded for entry of judgment consistent with its decision.

Holdings

1. An employer's retaliatory discharge of an at-will employee who internally reports violations of statutes and administrative regulations concerning forged dementia-training documents violates Iowa public policy. Internal whistleblowing may be protected even when the employee does not make an external report to the regulatory agency.
2. Punitive damages are not recoverable because, at the time of Dorshkind's discharge, Iowa had not recognized a public-policy exception to at-will employment based on the administrative-rule violation at issue.

Questions Presented

1. Whether an at-will employee who internally reports an employer's forgery of state-mandated dementia-training documents engages in protected activity under Iowa's public-policy exception to the at-will employment doctrine.
2. Whether punitive damages are recoverable for a wrongful-discharge claim based on a violation of administrative rules when Iowa had not recognized that public-policy basis at the time of the discharge.

Disposition

other