UPDATES & ANALYSIS

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Iowa Supreme Court: Punitive damages are not available under the Iowa Civil Rights Act

by Ryan Koopmans | June 21, 2013

By Ryan Koopmans

A unanimous Iowa Supreme Court ruled this morning in Ackelson v. Manley Toy Direct, Chief Justice Cady writing, that punitive damages cannot be awarded under the Iowa Civil Rights Act.  In doing so, the Court reaffirmed the same ruling from its 1986 decision in Chauffeurs, Teamsters & Helpers, Local Union No. 238 v. Iowa Civil Rights Commission.  The plaintiffs in this case–and almost every other discrimination case in Iowa over the last five years–had argued that Chauffeurs was out of style, and that the Supreme Court itself had weakened the no-punitive-damages rule in later decisions.

Not so, said the seven-justice court.  Citing Manley Toy’s “strong countervailing argument,” Chief Justice Cady noted that the Iowa Supreme Court has, on several occasions, mentioned the no-punitive-damages rule (even if in dicta), and yet the Iowa legislature has done nothing to amend the relevant statutory language, even though it has amended other parts of the Iowa Civil Rights Act.

(Disclosure: Nyemaster Goode represents Manley Toy Direct.)

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