Matthew Lewis Hunter v. City of Des Moines, Iowa

Summary

The Iowa Supreme Court reviewed a disability-discrimination and failure-to-accommodate action brought by former Des Moines police sergeant Matthew Lewis Hunter under the Iowa Civil Rights Act. The court held that Hunter’s disability-discrimination claim was properly submitted to the jury but that a flawed jury instruction required a new trial, and it held that the failure-to-accommodate claim failed as a matter of law. The court affirmed the court of appeals, reversed the district court judgment, and remanded for a new trial limited to the disability-discrimination claim.

Holdings

1. A diagnosis of PTSD does not, as a matter of law, render a law-enforcement officer unqualified. Because the evidence could support a finding that Hunter could perform the essential functions of the position with or without reasonable accommodation, the qualification issue was properly submitted to the jury.
2. Hunter presented sufficient evidence to create a jury question on whether his PTSD disability was a motivating factor in the City's termination decision.
3. Hunter's request for time and treatment made after his terminable misconduct and after termination had been recommended was too late to support a failure-to-accommodate claim.
4. The stereotypes instruction was erroneous because it permitted the jury to find unlawful discrimination based on unrecognized or unconscious bias and treatment different from how the employee would have been treated without a disability, without requiring proof of intentional discrimination because of disability and the other elements of a disparate-treatment claim.
5. The district court properly refused the City's proposed rules-of-conduct instruction because existing instructions adequately addressed termination for misconduct and the same-decision defense. It also properly refused the proposed comparator instruction because requiring identical conduct without mitigating or distinguishing circumstances was too restrictive.

Questions Presented

1. Whether sufficient evidence supported submitting Hunter's disability-discrimination claim to the jury, including whether he was qualified to perform the essential functions of a police officer and whether his disability was a motivating factor in his termination.
2. Whether Hunter's request for time and treatment as an accommodation, made after his misconduct and after termination had been recommended, was timely and legally sufficient to support a failure-to-accommodate claim.
3. Whether the district court's stereotypes jury instruction misstated the law by allowing liability without proof of intentional discrimination because of disability.
4. Whether the district court properly refused the City's proposed rules-of-conduct and comparator-evidence jury instructions.

Disposition

reversed_and_remanded