IA Supreme Court clarifies employee's burden of proof in disability discrimination cases

The Iowa Supreme Court recently provided needed clarity in what it described as the "murky" intersection between workers' compensation and disability discrimination claims.

Facts

Ronald Rumsey, who has a preexisting disability (a hearing impairment), suffered an injury while working for Woodgrain Millwork, Inc. While he was rehabilitating the injury, the employer placed him on light-duty work. While the accommodation was in effect, the parties disagreed over his alleged entitlement to a specific work restriction, and he was fired:

• Rumsey claimed he was seeking a reasonable accommodation for his disability.
• Woodgrain Millwork argued the termination was triggered by his insubordination.

At trial, the jury found in Rumsey's favor and awarded him $58,000 in back pay as well as $300,000 for past and $150,000 for future emotional distress damages.

Court sides with employer

On appeal, the Iowa Supreme Court reversed the district court's denial of Woodgrain Millwork's request at trial that the judge determine the outcome instead of the jury, finding the employer was entitled to the dismissal of Rumsey's discrimination claims. The court then sent the case back for further proceedings on the former employee's claims that the employer failed to accommodate and retaliated against him for requesting a sign language interpreter.

In its 42-page ruling, the court made the following points about disability discrimination claims: