Ackerman v. Iowa, No. 20-2226 (8th Cir. 2021)
Annotate this Case
The Eighth Circuit affirmed the district court's grant of summary judgment in favor of defendants in an action alleging retaliation, defamation, and intentional infliction of emotional distress claims against plaintiff's former employer, Workforce Development and the state of Iowa, as well as against certain former supervisors and coworkers. Plaintiff's claims stemmed from her termination as an ALJ based on allegations that she fraudulently filed insurance enrollment forms and had deliberately falsified her daughter's marital status. Plaintiff alleged that her termination was based on retaliation for her testimony before the Oversight Committee and that the insurance fraud investigation constituted a mere pretext.
In regard to the whistleblower retaliation claim, the court concluded that plaintiff failed to present evidence from which a reasonable jury could find that she was suspended or terminated in reprisal for her testimony. In regard to the defamation claim, the court concluded that Defendant Wahlert was entitled to summary judgment with respect to her allegedly defamatory testimony to the Oversight Committee where her testimony and related actions were within the scope of her employment. The court also concluded that plaintiff failed to establish any constitutional violation as to the First Amendment retaliation claim; defendants' conduct was not sufficiently egregious to satisfy the outrageousness prong of the Iowa tort of intentional infliction of emotional distress; and the district court did not err in granting summary judgment on plaintiff's retaliation claim based on the Iowa Constitution's free speech clause.
Court Description: [Wollman, Author, with Colloton and Kobes, Circuit Judges] Civil case - Employment law. In action challenging plaintiff's termination as an ALJ, the district court did not err in determining there was not a genuine issue of material fact that plaintiff's testimony before an Iowa legislative committee did not cause her discipline or termination; defendant Wahlert's testimony before the Committee was within the scope of her employment as director of plaintiff's branch, and she was entitled to summary judgment based on qualified immunity with respect to her allegedly defamatory testimony; the defendants were entitled to summary judgment on plaintiff's First Amendment retaliation claims as they were either not involved in her discipline and discharge or were able to present an independent, non-retaliatory basis for plaintiff's suspension and termination, and plaintiff failed to show the stated ground was pretextual; defendants were entitled to summary judgment on plaintiff's state law claim for intentional infliction of emotional distress as defendants' conduct was not sufficiently egregious to satisfy the outrageousness prong of the Iowa tort; in light of the court's holding that plaintiff failed to establish a violation of her federal constitutional right to free speech, she similarly failed to establish a violation of her state constitutional right to free speech.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.