Iowa Court Says No Punitive Damages for Civil Rights Claims

In Ackelson v. Manley Toy Direct L.L.C., the Supreme Court of Iowa held that punitive damages could not be awarded in a case brought under the Iowa statutes that prohibit employment discrimination. The Court determined that the statutes provided recovery for reasonable attorney fees, court costs and actual damages only. In reaching this decision, the Court reasoned that since 1986 it has held in a number of cases that the Iowa Civil Rights Act does not explicitly or implicitly provide a recovery for punitive damages. Further justification for the decision was that there was no indication of any legislative intent to allow punitive damages. The legislature did not amend the Iowa Civil Rights Act to allow for punitive damages even though the federal and some state statutes had been amended in this manner. The Court determined that imposing punitive damages was a public policy issue which involved the weighing of the deterrence of discrimination against the detriment to the employer.

The three female employees filed the lawsuit of alleged sexual harassment by a supervisor and another employee who were both male. The alleged harassment included vulgar remarks, demeaning statements and discussions of the supervisor’s personal sex life. Allegations of discrimination and retaliation were also made by the female employees. The opinion was issued on June 21, 2013 and only addressed whether the female employees could recover punitive damages. The case was remanded to the lower court to proceed on the other issues.

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