Posted on 05/21/2018 at 08:06 AM by Bryan O'Neill
The Iowa Supreme Court issued its Opinion in Jahnke v. Deere & Company, et al., a case in which the Court was asked to decide 1) whether the Iowa Civil Rights Act (“ICRA”) applied extraterritorially, and 2) whether the facts of the plaintiff’s claims occurred in Iowa. In answering both questions in the negative, the Court remanded the case back to the district court for entry of judgment in favor of Deere & Company (“Deere”).
The plaintiff, Matthew Jahnke (“Jahnke”) was a nearly twenty-year employee of Deere. In 2011, he began a temporary assignment for Deere as a project manager for a Deere subsidiary in Harbin, China. Previous to that, Jahnke had been employed at the John Deere Des Moines Works in Ankeny. When Jahnke accepted the assignment in China, he sold his home in Iowa, but later maintained a post office box in Bettendorf. While in China, Jahnke purchased homes in Florida and Australia. He variously identified his primary address as Florida or Beijing.
In 2014, Deere conducted an investigation into Jahnke’s relationship with two woman who worked for or on behalf of Deere. The committee investigating Jahnke was made up of Deere employees that worked in either China or Deere’s home office in Moline, Illinois. Deere’s investigation concluded that Jahnke had engaged in a sexual relationship with both women who were within his span of control. As a result, the committee made the decision to repatriate Jahnke back to the United States. Deere reassigned Jahnke to a position at a lower pay grade working at the Deere factory in Waterloo.
Jahnke filed a complaint with the Iowa Civil Rights Commission (“ICRC”), alleging Deere’s actions were motivated by his age, national origin, and sex. Once a lawsuit was instituted, Deere moved for summary judgment on all of Jahnke’s claims on the basis that Jahnke was geographically and jurisdictionally beyond the ICRA’s reach. The district court denied Deere’s motion, and Deere applied for and was granted an interlocutory appeal.
The Iowa Supreme Court first held that the ICRA did not apply extraterritorially. “Unless the intention to have a statute operate beyond the limits of the state or country is clearly expressed or indicated by its language, purpose, subject matter, or history, no legislation is presumed to be intended to operate outside the territorial jurisdiction of the state or country enacting it.” The Court noted that “nothing in the language of the ICRA expressly states or indicates that it applies extraterritorially.” Moreover, the language within the ICRA only authorized the ICRC to investigate discrimination “in this state . . . .”
The Court next held that the facts as alleged did not involve a discrete discriminatory employment action that occurred in Iowa. The members of the committee that investigated Jahnke were located in China and in Moline, Illinois. The Court also dismissed Jahnke’s arguments that his post office box in Bettendorf or Deere’s operations in Iowa somehow permitted him to properly bring a claim in Iowa. “Nothing in the ICRA demonstrates an intent for the ICRA to apply to discrimination claims made against an employer simply because of the parties’ tangential relations with Iowa in cases where the alleged discrimination took place outside of Iowa.”
Finally, the Court said that Jahnke had a remedy under laws other than the ICRA. He could have brought his claims under federal laws (here, Title VII, the Age Discrimination in Employment Act), or a corresponding state statute in Illinois.
The Court’s opinion was unanimous, with Justices Hecht and Mansfield taking no part.
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- Bryan O'Neill
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