John Deere wins case filed by fired manager; Iowa civil rights law can't extend to China

By Elizabeth Alt | May 30, 2018

DES MOINES, Iowa (Legal Newsline) – The Iowa Supreme Court stated that the Iowa Civil Rights Act cannot extend extraterritorially on May 18, granting summary judgment to Deere & Co. in a former manager’s lawsuit claiming civil rights violations under the Iowa Civil Rights Act after he was fired.

DES MOINES, Iowa (Legal Newsline) – The Iowa Supreme Court stated that the Iowa Civil Rights Act cannot extend extraterritorially on May 18, granting summary judgment to Deere & Co. in a former manager’s lawsuit claiming civil rights violations under the Iowa Civil Rights Act after he was fired.  

Judge Bruce B. Zager issued the court opinion that reversed an earlier decision from the Iowa District Court for Polk County. Zager stated that the incidents the man was fired for - allegedly having sexual relationships with two women he was supervising that were unreported - occurred in China where the man had established residency, not Iowa.  

“The ICRA does not apply to employment actions that occurred outside of Iowa solely because some of the people involved in those actions may have had contact with Iowa,” the order stated.

According to the opinion, Matthew Jahnke had been an employee for Deere & Co., known for its John Deere tractors, for more than 10 years when he was hired as a factory manager for a new branch in China in 2011. Jahnke sold his home in Iowa where he’d been living and working for Deere and lived in China until 2014. 

Jahnke was demoted and transferred back to Iowa when Deere officials discovered that Jahnke had violated its code of conduct by having sexual relationships with two Chinese women whom Jahnke supervised. Jahnke sued Deere under the ICRA, claiming that “Deere discriminated against him based on his age, sex, and national origin,” according to the order.

The district court denied Deere’s motion for summary judgment. Deere appealed, arguing that the district court erred because “the Iowa Civil Rights Act did not apply extraterritorially and that Jahnke based his claims on allegations of discriminatory acts that occurred outside of Iowa,” the order stated.

Jahnke claimed that the ICRA applies to his case "because it involves an Iowan working on temporary assignment in China, who was discriminated against by Iowans who made their discriminatory decisions in Iowa," according to the order.

The Supreme Court reversed the district court ruling, stating, “we cannot agree with the district court that the ICRA applies to this case simply due to the parties’ contacts with Iowa. The district court erroneously expanded the ICRA beyond its reach...”

Zager commented that nothing in the ICRA indicates that the statute would apply extraterritorially.  

“If the Iowa legislature wanted the ICRA to apply extraterritorially, it would have expressly indicated this intent in the statutory text,” the order states.

Zager stated that the Supreme Court is “unwilling to expand the reach of the ICRA to apply extraterritorially,” and issued an order remanding the case back to district court to award summary judgment to Deere. 

The plaintiff is represented by Paige Fiedler and Nathan Borland of Fiedler & Timmer PLLC, Johnston; and Roxanne Barton Conlin of Roxanne Conlin & Associates PC in Des Moines, Iowa.

The defendants are represented by Frank Harty and Debra Hulett of Nyemaster Goode PC in Des Moines. 

Supreme Court of Iowa case number 17–0638

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