Iowa Code § 216.6
Unfair employment practices: the cases that interpreted this section
225 citing cases reviewed of 334 in the citation index: 159 interpreted the section (annotated below), 66 cited it only in passing. Cases filed after 2026-05-13 may not have been reviewed yet.
Have a situation under Iowa Code § 216.6?
These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.
Sex discrimination in grooming codes
Section 216.6(1)(a) prohibits sex discrimination in employment; a discharge claim requires evidence supporting an inference that the termination was based on sex.
Mayorga v. Marsden Building Maintenance · filed 2022-12-20(1)(a)
The ICRA prohibits discrimination in employment based on an applicant’s or employee’s sex. See Iowa Code § 216.6(1)(a). ... But none of the evidence she presented supports a reasonable inference that Velasquez’s decision to fire her is “more likely than not” explained by an intent to discriminate against her on the basis of her sex.Read the full opinion on CourtListener →
A sex discrimination claim under section 216.6(1)(a) requires an adverse employment action and circumstances supporting an inference of discrimination.
Reiter v. State of Iowa and Iowa Department of Education · filed 2026-05-13(1)(a)
The ICRA prohibits discrimination in employment based on ten specific characteristics: “age, race, creed, color, sex, sexual orientation, gender identity, national origin, religion, or disability.” Iowa Code § 216.6(1)(a). To establish a prima facie case of discrimination in employment based on sex, Reiter must show (1) he is a member of the protected group; (2) he was qualified to perform the job; (3) he suffered an adverse employment action; and (4) the circumstances allow an inference of discrimination. ... Upon our review, we find the summary judgment record does not raise an inference of sex discrimination.Read the full opinion on CourtListener →
Federal preemption
Section 216.6 employment discrimination claims against individual Federal Home Loan Bank defendants are preempted when individual liability conflicts with federal antidiscrimination law.
Ewing v. Federal Home Loan Bank of Des Moines · filed 2009-08-04
Indisputably, this means that Plaintiffs claims against the individual Defendants, Swanson, Spaeth, and Guttau, are preempted because individual liability against those defendants is impermissibly in conflict with both Title VII and the ADEA.Read the full opinion on CourtListener →
Sexual orientation discrimination
Section 216.6(1)(a) prohibits employment discrimination based on sexual orientation.
Robertson v. Siouxland Community Health Center · filed 2013-04-10(1)(a)
On the other hand, the ICRA expressly prohibits discrimination based on “sexual orientation,” ... so that Robertson’s claims of discrimination and harassment based on sexual orientation may proceed under state law.Read the full opinion on CourtListener →
Section 216.6(1)(a) prohibits discharge based on sexual orientation, and a decisionmaker’s derogatory remarks can create a factual issue about discriminatory motive.
Christie v. Crawford County Memorial Hospital and Bill Bruce · filed 2018-07-18(1)(a)
Bruce’s statements are direct evidence of a possible discriminatory motive by the decisionmaker in violation of the ICRA. See Iowa Code § 216.6(1)(a). On this record, summary judgment was not warranted, and we reverse.Read the full opinion on CourtListener →
Geographic scope of employment discrimination claims
Section 216.6 requires a disparate treatment claimant to show a discriminatory employment action within the scope of employment in Iowa; tangential Iowa contacts are insufficient.
Jahnke v. Deere and Company, Richard Czarnecki, and Bernhard Haas · filed 2018-05-18(1)
A complainant bringing such a claim must show a discrete discriminatory employment action that took place within the scope of employment in Iowa. See Dindinger v. Allsteel, Inc., 860 N.W.2d 557, 570 (Iowa 2015); Rent-A-Center, Inc., 843 N.W.2d at 734; see also Iowa Code § 216.6.Read the full opinion on CourtListener →
Section 216.6(1)(a) requires evidence that an employer’s stated reason for termination was pretextual to sustain an age or sex discrimination claim at summary judgment.
Iverson v. DECO Products Company, LLLP · filed 2020-01-22(1)(a)
Iverson claims that his termination constituted age and sex discrimination under state and federal law. See Age Discrimination in Employment Act (ADEA), 29 U.S.C. § 623(a)(1); Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e-2(a)(1); Iowa Civil Rights Act (ICRA), Iowa Code § 216.6(1)(a). ... This evidence is insufficient to establish that the proffered reason for terminating Iverson—that a second woman complained he engaged in sexual harassment—was pretextual. Accordingly, Deco Products is entitled to summary judgment on Iverson’s claims for age and sex discrimination under federal and Iowa law.Read the full opinion on CourtListener →
Same-decision defense
Section 216.6(1)(a) uses a motivating-factor standard for employment discrimination and allows a same-decision defense instruction if the defense is properly pled and proved.
Hawkins v. Grinnell Regional Medical Center · filed 2019-06-07(1)(a)
Therefore, in discrimination and retaliation cases under ICRA, we apply the Price Waterhouse motivating-factor standard in instructing the jury and the defendant is entitled to an instruction on the same-decision defense recognized in Price Waterhouse if properly pled and proved.Read the full opinion on CourtListener →
Employee status of prison inmates
Section 216.6 does not categorically exclude inmates from its employment discrimination protections.
Renda v. Iowa Civil Rights Commission · filed 2010-06-04(6)
The fact that the legislature did not provide an explicit exception for inmates within the Act leads us to believe that the legislature did not intend one.Read the full opinion on CourtListener →
Notes 151–159 of 159, oldest cases first.
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